Resolution - Mitigation Program Report — Riverside City Council, December 17, 2024

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RESOLUTION NO. A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF RIVERSIDE, CALIFORNIA, APPROVING THE VEHICLE MILES TRAVELED (VMT) MITIGATION BANK PROGRAM AND ESTABLISHING A MITIGATION FEE FOR PURCHASE OF VMT MITIGATION BANK PROGRAM VMT UNITS PURSUANT TO PROVISIONS OF SECTION 16.80.040 OF THE RIVERSIDE MUNICIPAL CODE WHEREAS, Senate Bill (“SB”) 743 determined that the appropriate metric for analyzing traffic impacts in California Environmental Quality Act (“CEQA”) documents is Vehicle Miles Traveled (“VMT”); and
WHEREAS, the City of Riverside (“City”) adopted VMT thresholds of significance for purposes of analyzing transportation impacts under CEQA on June 16, 2020; and WHEREAS, the City wishes to establish a program to streamline and facilitate compliance with the requirements of SB 743; and
WHEREAS, the City has found that project-by-project VMT mitigation can be infeasible, inconsistent, and a pooled approach will help the City better mitigate VMT impacts; and WHEREAS, in February of 2023, the City retained Kimley-Horn and Associates, Inc. (“Kimley-Horn”) to analyze the specific mitigation measures that could be included in the City’s VMT mitigation program and to evaluate the feasibility of a fee-based VMT mitigation program.

Kimley-Horn issued a report (“VMT Mitigation Report”), dated October 17, 2024, as set forth in Exhibit “A” attached hereto and incorporated herein, that recommended the adoption of a proposed VMT Mitigation Bank Program.

WHEREAS, the VMT Mitigation Report analyzed an option to include bicycle project mitigation measures only in the proposed VMT Mitigation Bank Program and setting the cost at Ninety-Eight Dollars ($98.00) per VMT unit; and
WHEREAS, on November 21, 2024, the Planning Commission considered the proposed VMT Mitigation Bank Program, and related VMT Mitigation Fee ordinance amending Title 16 of the Riverside Municipal Code by adding Chapter 16.80; and WHEREAS, on December 9, 2024, the Land Use Committee considered the proposed VMT Mitigation Bank Program, and related VMT Mitigation Fee ordinance; and

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WHEREAS, on December 17, 2024, the City Council held a duly noticed public hearing on the VMT Mitigation Bank Program and related VMT Mitigation Fee and received and considered the reports and recommendation from the Planning Commission and all other testimony, whether written or oral, presented at the public hearing.

NOW THEREFORE, BE IT RESOLVED by the City Council of the City of Riverside, as follows:

Section 1: That the foregoing recitals are true, correct and a substantive part of this resolution.

Section 2: That the proposed Vehicle Miles Traveled (“VMT”) Mitigation Bank Program and VMT Mitigation Fee amendment to Title 16 of the Riverside Municipal Code adding Chapter 16.80 are consistent with the City’s General Plan.

Section 3: The City Council has reviewed the VMT Mitigation Bank Program and VMT Mitigation Fee ordinance and determined that the components and the VMT Mitigation Bank Program and the related VMT Mitigation Fee itself are exempt from CEQA review pursuant to Sections 15378, 15061(b)(3) and 15262 of the CEQA Guidelines.

Section 4: That the City Council hereby direct Community and Economic Development staff to file the Notice of Exemption with the Riverside County Clerk.

Section 5: That the City Council hereby approves and adopts the Vehicle Miles Traveled Mitigation Bank Program with the inclusion of bicycle project mitigation measures only.

Section 6: Pursuant to section 16.80.040 of the Riverside Municipal Code, the City Council hereby adopts the VMT Mitigation Fee of Ninety-Eight Dollars ($98.00) per VMT Unit.

Section 7: This resolution shall take effect concurrent with the effective date of Chapter 16.80.
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ADOPTED by the City Council this ____ day of _______________, 2024.

_________________________________

PATRICIA LOCK DAWSON
Mayor of the City of Riverside

Attest:

__________________________

DONESIA GAUSE
City Clerk of the City of Riverside

I, Donesia Gause, City Clerk of the City of Riverside, California, hereby certify that the foregoing resolution was duly and regularly adopted at a meeting of the City Council of said City at its meeting held on the _____ day of ________________, 2024, by the following vote, to wit:

Ayes:

Noes:

Absent:

Abstain:

IN WITNESS WHEREOF, I have hereunto set my hand and affixed the official seal of the City of Riverside, California, this ______ day of _______________, 2024.

_____________________________

DONESIA GAUSE
City Clerk of the City of Riverside

\\Rc-citylaw\cycom\WPDOCS\D007\P049\00892016.DOC
[24-1793.1] TAT 11/07/24
Vehicle Miles Traveled (VMT) Mitigation
Program
Draft Report
October 17, 2024
EXHIBIT "A"
City of Riverside
VMT Mitigation Program
Acknowledgements
The City of Riverside, along with stakeholders and partner agencies, worked to complete a study that evaluates programmatic options that mitigate Vehicle Miles Traveled (VMT) to meet the requirements of the California Environmental Quality Act (CEQA) for the City of Riverside. The study was managed by Philip Nitollama, PE, TE, and Vital Patel of the City’s Department of Public Works, Traffic Engineering Division, in coordination with a Stakeholder Advisory Committee. A consulting team led by Kimley-Horn and Associates assisted the City of Riverside and the SAC in completing the study.

Project Partners
City of Riverside Public Works
· Philip Nitollama, PE, TE
· Vital Patel
· Nathan Mustafa, PE, TE, AICP
City of Riverside Community Economic Development
· Maribeth Tinio,
· Matthew Taylor
University of California, Riverside
· Irma Henderson
County of Riverside
· Kevin Tsang, PE
· Dennis Acuna, PE, TE
Western Riverside Council of Governments
(WRCOG)
· Chistopher Tzeng
Riverside Transit Agency (RTA)
· Jennifer Nguyen
Consultant Team
Kimley-Horn:
· Michael Schmitt, AICP CTP, PTP, RSP1
· Chris Gregerson, PE, TE, AICP, PTP
Additional Guidance From
Project Stakeholder Advisory Committee

City of Riverside
VMT Mitigation Program
Table of Contents
Executive Summary ............................................................................................................................ ES-1 Recommended VMT Mitigation Program and Mitigation Measures ................................................ ES-2 Study Activities and Results ............................................................................................................ ES-3 Study Findings and Recommendations............................................................................................ ES-5 Introduction ............................................................................................................................................ 1 Existing City of Riverside SB 743 Policy..................................................................................................... 3 Outreach Summary ................................................................................................................................. 5 Establishing Mitigation Need ................................................................................................................... 9 VMT Evaluation Tool ............................................................................................................................. 11 VMT Mitigation Measures ..................................................................................................................... 12 Fee-Based VMT Mitigation Program Framework Options ................................................................... 14 VMT Bank ...................................................................................................................................... 15 VMT Exchange ............................................................................................................................... 17 VMT Impact Fee............................................................................................................................. 17 Program Evaluation ............................................................................................................................... 20 Identifying and Evaluating VMT Mitigation Measures ............................................................................ 22 Bicycle Mitigation Measures Evaluation ......................................................................................... 22 Pedestrian Mitigation Measure Evaluation..................................................................................... 27 Transit Mitigation Measure Evaluation .......................................................................................... 29 Transportation Demand Management (TDM) Mitigation Measures ................................................... 31 Telecommute: Work-From-Home (WFH) Every Day ....................................................................... 31 Telecommute: Work-From-Home (WFH) Once a Week .................................................................. 31 Recommended VMT Mitigation Measures ............................................................................................. 32 CEQA/Nexus Considerations .................................................................................................................. 37 Feasible Mitigation Considerations .................................................................................................... 37 Economic Feasibility ...................................................................................................................... 38 Nexus Documentation ....................................................................................................................... 39 Proposed ........................................................................................................................................... 39 Existing Case Law ............................................................................................................................... 40 Additional Considerations .................................................................................................................. 40 Case Studies .......................................................................................................................................... 41 City of Riverside
VMT Mitigation Program
Implementation..................................................................................................................................... 43 Additional Study Outcomes ................................................................................................................... 45 Appendices
Appendix A – Literature Review and Existing Case Law
Appendix B – State of the Practice
Appendix C – Outreach Materials
Appendix D – Riverside TREDLite VMT Quick Guide
Appendix E – VMT Mitigation Bank Program and CEQA Clearance Appendix F – Categorical Exemption for the City of Riverside VMT Mitigation Program City of Riverside
VMT Mitigation Program
List of Tables
Table 1 – Potential Land Use Growth and VMT to Mitigate, 2018 to 2045 ............................................... 9 Table 2 – Summary of Bike Mitigation Measure Evaluation ................................................................... 23 Table 3 – Bike Mitigation Measures with Cost/VMT Reduced less than $2,000 ...................................... 26 Table 4 – Summary of Pedestrian Mitigation Measures Considered for Evaluation ................................ 28 Table 5 – Summary of Pedestrian Mitigation Measure Evaluation ......................................................... 29 Table 6 – Summary of Transit Mitigation Measure Evaluation ............................................................... 30 Table 7 – Summary of TDM Mitigation Measure Evaluation................................................................... 31 Table 8 – Recommended VMT Mitigation Measures (Option A) ............................................................. 32 Table 9 – Recommended VMT Mitigation Measures (Option B) ............................................................. 33 Table 10 – Recommended VMT Mitigation Measures (Option C) ........................................................... 35 Table 11 – Pilot Program VMT Mitigation Measures .............................................................................. 43 Table 12 – Existing Case Law Relevant to Developing a VMT Mitigation Program .................. Appendix A-2 Table 13 – Fee-based VMT Mitigation Program State of the Practice .................................... Appendix B-1 List of Exhibits
Exhibit ES-1 – Level of Service vs. Vehicle Miles Traveled.................................................................... ES-1 Exhibit ES-2 – VMT Bank Framework .................................................................................................. ES-2 Exhibit ES-3 – VMT Mitigation Measures ............................................................................................ ES-3 Exhibit 1 – Level of Service vs. Vehicle Miles Traveled ............................................................................. 1 Exhibit 2 – Key Outreach Efforts Completed ............................................................................................ 5 Exhibit 3 – City of Riverside VMT Mitigation Program Project Website .................................................... 6 Exhibit 4 – City of Riverside VMT Mitigation Program Logo...................................................................... 8 Exhibit 5 – Residential VMT Mitigation Need by TAZ.............................................................................. 10 Exhibit 6 – Employment VMT Mitigation Need by TAZ ........................................................................... 10 Exhibit 7 – VMT Mitigation Measures .................................................................................................... 13 Exhibit 8 – VMT Mitigation Measure Ranking Criteria ............................................................................ 14 Exhibit 9 – Application of a VMT Mitigation Program............................................................................. 15 Exhibit 10 – VMT Bank Example ............................................................................................................ 16 Exhibit 11 – VMT Exchange Example ..................................................................................................... 17 Exhibit 12 – VMT Impact Fee Example ................................................................................................... 18 Exhibit 13 – VMT Impact Fee Program with Multiple Benefit Areas ....................................................... 19 Exhibit 14 – VMT Mitigation Program Evaluation ................................................................................... 20 Exhibit 15 – Types of Bicycle Improvements Evaluated for the City of Riverside ..................................... 23 Exhibit 16 – Location of Bicycle Improvements Resulting in a Cost Less than $2,000/VMT Reduced....... 26 City of Riverside
VMT Mitigation Program
Abbreviations
BRT – Bus Rapid Transit
CAPCOA – California Air Pollution Control Officers Association CBO – Community Based Organization(s)
CEQA – California Environmental Quality Act
EIR – Environmental Impact Report
HCM – Highway Capacity Manual
LOS – Level of Service
LRSP – Local Roadway Safety Program
NCHRP – National Cooperative Highway Research Program
RCTC – Riverside County Transportation Commission
RIVCOM – Riverside County Model
Riverside PACT – Program consisting of a Pedestrian Target Safeguarding Plan (PTS), an Active Transportation Plan (AT Plan), a Complete Streets Ordinance (CSO), and a Trails Master Plan (TMP) RTA – Riverside Transit Agency
RTP/SCS – Regional Transportation Plan/Sustainable Communities Strategy SAC – Stakeholder Advisory Committee
SB – Senate Bill
SEIR – Supplemental Environmental Impact Report
SS4A – Safe Streets for All
TAZ – Traffic Analysis Zone
TDM – Transportation Demand Measure(s)
TPA – Transit Priority Area
UCR – University of California, Riverside
VMT – Vehicle Miles Traveled
WFH – Work-from-Home
WRCOG – Western Riverside Council of Governments
ES-1
City of Riverside
VMT Mitigation Program
Executive Summary
T h i s s t u d y e v a l u a t e s p r o g r a m o p t i o n s t h a t m i t i g a t e V e h i c l e M i l e s T r a v e l e d ( V M T ) t o m e e t t h e requirements of the California Environmental Quality Act (CEQA) for the City of Riverside. Entities such as the California Department of Transportation (Caltrans) and the University of California Riverside (UCR), could also potentially use the program to mitigate VMT impacts. The goal of the study is to establish a framework for offsite mitigation of VMT for development projects that are not able to mitigate the entirety of their impacts onsite. The VMT mitigation program would fund active transportation, transit, and other VMT reducing measures such as transportation demand management (TDM) programs throughout the City that decrease VMT and greenhouse gas (GHG) emissions, improve safety, combat climate change, and improve the quality of infrastructure within disadvantaged communities.

California's Senate Bill (SB) 743 represents a significant shift in evaluating transportation impacts under the California Environmental Quality Act (CEQA), moving from congestion measures to vehicle miles traveled (VMT) for assessing land use projects and transportation improvements. Historically, transportation impacts were measured using Level of Service (LOS), a concept established in the Highway Capacity Manual (HCM), which evaluated impacts based on drivers' experiences and assigned grades from “A” to “F.” However, focusing on LOS has led to unintended consequences such as urban sprawl, increased vehicular travel (induced demand), and negative impacts on active transportation, public transit, and public health. SB 743 shifts the metric to VMT, a more holistic measure considering the total miles traveled by vehicles due to a project, encouraging urban infill development, and promoting active transportation and transit use. This shift aims to foster sustainable development patterns, reduce greenhouse gas emissions, and mitigate environmental impacts associated with vehicular travel. By focusing on VMT, SB 743 aligns with California's broader sustainability goals, creating more sustainable and livable communities through integrated transportation and land use planning. Exhibit ES-1 provides a summary of the differences between LOS and VMT.

Exhibit ES-1 – Level of Service vs. Vehicle Miles Traveled With the change to VMT as the primary transportation performance metric, new types of mitigations have become necessary, as solutions addressing LOS impacts often differ from those that address VMT impacts.

ES-2
City of Riverside
VMT Mitigation Program
For example, adding a new left-turn lane at an intersection to reduce delay and improve LOS would not help mitigate a VMT impact. Initially, agencies across the state have relied on site-specific improvements, land use solutions, and transportation demand measures (TDM) to mitigate VMT impacts. However, these solutions have often been insufficient to address significant transportation impacts for new projects.

Consequently, there is growing interest in identifying new solutions to meet the increasing need for VMT mitigation. This study evaluates the feasibility and implementation of a VMT mitigation program, which seeks to monetize VMT mitigation measures so that projects can obtain VMT mitigation proportional to their need. These programs aim to make various VMT mitigation measures available to projects that would otherwise not be feasible to develop or could not otherwise obtain mitigation. By monetizing the mitigation process, these programs provide a more flexible and comprehensive approach to reducing vehicle miles traveled and promoting sustainable transportation development.

Recommended VMT Mitigation Program and Mitigation Measures The study resulted in a recommendation for a VMT mitigation bank as the preferred mitigation program framework. A VMT bank is designed to offer project applicants an opportunity to offset their VMT impacts by purchasing credits from a central repository of VMT mitigation measures. In the region, the VMT bank would function as a central entity collecting fees from project applicants whose projects have a significant transportation impact as defined by the member agency’s CEQA guidance and have not otherwise implemented sufficient VMT mitigation measures. These funds would be used by the program the City of Riverside to implement various VMT mitigation measures across the City. A graphical illustration of a VMT bank is shown in Exhibit ES-2.

Exhibit ES-2 – VMT Bank Framework
Various VMT mitigation measures are available for land use and transportation projects that need to reduce their VMT impacts. Several types of these measures can be considered for inclusion in the City’s VMT mitigation program, including those summarized in Exhibit ES-3.

ES-3
City of Riverside
VMT Mitigation Program
Exhibit ES-3 – VMT Mitigation Measures
This study analyzed the specific mitigation measures that could be included in the City’s VMT mitigation program. This involved the identification of mitigation categories that would undergo review before individual mitigation measures were selected for evaluation. Understanding a need for a diverse set of mitigation measures, both in terms of geographic location, as well as mitigation measure type, several different sources were used to develop potential mitigation measures. Potential mitigation measures were solicited from the Stakeholder Advisory Committee (SAC), existing City plans and documents such as the Riverside PACT1, the City’s Bicycle Master Plan 2, the Northside Specific Plan 3, and several one-on- one agency meetings. Mitigation measure categories in which individual mitigation measures were selected from included active transportation, transit, and TDMs.

Study Activities and Results
This summary highlights the critical actions taken during the study, focusing on the existing programs, stakeholder involvement, equity concerns, and CEQA considerations.

1. Literature Review:
o The literature review provided a comprehensive overview of Vehicle Miles Traveled (VMT) mitigation programs implemented across jurisdictions in California under SB 743. 1 The City of Riverside PACT: Pedestrian Target Safeguarding Plan (PTS), Active Transportation Plan (AT Plan), a Complete Streets Ordinance (CSO), and a Trails Master Plan (TMP). City of Riverside. https://riversideca.gov/pact. 2 City of Riverside Bicycle Master Plan. City of Riverside and Alta Planning + Design. Adopted May 22, 2007. 3 Northside Neighborhood & Pellissier Ranch Specific Plan. City of Riverside. Adopted November 17, 2020.

ES-4
City of Riverside
VMT Mitigation Program

2. Outreach:
o The major components of the Outreach Plan included a Stakeholder Advisory Committee (SAC), targeted stakeholder outreach, a public meeting, a study website and online survey, social media posts, and branding.

3. VMT Mitigation Needs Assessment:
o Through 2045, it is estimated that 191,800 residential VMT and 299,000 employment VMT will need to be mitigated.

4. VMT Evaluation Tool:
o An online VMT Evaluation Tool for estimating development project VMT impacts was developed and tested with multiple example development projects, providing a practical demonstration of its capabilities to the SAC.

5. Evaluation Criteria and Program Framework:
o Criteria for VMT mitigation measures and program frameworks were established.

6. Mitigation Measure Assessment
o A variety of mitigation measures, identified by the SAC or contained within the Riverside PACT and the Northside Specific Plan, were identified for consideration including active transportation, transit, TDM, and other categories.
o 29 bicycle and 11 pedestrian improvements were identified with all bicycle improvements and three pedestrian improvements evaluated for inclusion in the City’s program. The evaluation resulted in sixteen bicycle improvements achieving a cost per VMT reduction of less than $2,000. The pedestrian improvements ranged in a cost per VMT reduction between $22,222 and $41,667.
o Six transit projects were evaluated, with a cost per VMT reduction ranging between $1,396 and $2,582.
o Two TDM programs, both work-from-home programs, were evaluated resulting in a cost per VMT reduction ranging between $221 and $1,106.

7. Recommendations:
o Three options of mitigation measure combinations were developed to be recommended for inclusion in the City’s VMT mitigation program. Option A resulted in the lowest cost per VMT reduction at $98 but contains the least amount of VMT available and only contains bicycle measures. Option B includes all bicycle measures from Option A, but also includes six additional transit measures resulting in a cost per VMT reduction of $1,192.

Option C builds on Option B by adding two pedestrian measures achieving the highest amount of VMT available and the highest cost per VMT reduction at $1,287.

ES-5
City of Riverside
VMT Mitigation Program

8. CEQA Considerations:
o A VMT Bank is ex empt from CEQ A as per CE QA Gu id elines S ec t ion 15378, but spec ific mitigation measures implemented as part of a VMT bank will still require environmental review.
o The City will consider a program EIR for the upcoming General Plan update to address economic feasibility and allow for tiering of individual projects that are consistent with the General Plan.

Study Findings and Recommendations
Findings and recommendations that have resulted from the study include:
· Project Uncertainty Without a VMT Mitigation Solution : Without a clearly defined VMT mitigation program, many projects will face significant uncertainty, potentially stalling progress, even if they align with other plans and programs.
· VMT Mitigation Program as a Solution: A VMT mitigation program offers a new, viable option for addressing VMT impacts that cannot be mitigated through other methods. A VMT bank program is recommended as the most suitable approach for implementation of the City’s VMT mitigation program.
· Selectivity in Mitigation Measures : It is crucial to carefully select VMT-reducing mitigation measures to ensure financial and practical feasibility. These measures should be evaluated for alternative funding sources and compliance with additionality requirements. · Ongoing Process : D e v e l o p i n g m i t i g a t i o n m e a s u r e s f o r t h e C i t y ’ s p r o g r a m w i l l b e a n o n g o i n g process, necessitating accurate methods of VMT analysis in line with best analysis practices to ensure robust outcomes. This study’s established framework should serve as the basis for future analysis.
· Voluntary Pilot Program: It is recommended that the City’s VMT mitigation program initially be structured as a voluntary pilot program rather than fully implemented at the onset. A voluntary p i l o t p r o g r a m w i l l a l l o w t h e C i t y a n o p p o r t u n i t y t o e v a l u a t e t h e p r o g r a m a n d m a k e a determination as to whether it meets the City’s objectives and/or whether additional program modifications may be appropriate. A voluntary pilot program can also be conducted with a less formal structure that can provide for needed flexibility during its initial evaluation. · Support and Participation from Everyone : The program’s success hinges on support from decision-makers, agencies, the community, and participants in the City’s VMT mitigation program. · Periodic Price Changes: If the City’s VMT mitigation program is ultimately implemented the price per VMT reduced may change periodically as the composition of the program and additional funding measures are identified. The prices are current as of publication of this document but should be considered the current price of the program and not the price per VMT reduced in perpetuity.
· Set VMT Threshold at Regional Average: it is recommended that the City of Riverside set its VMT significance thresholds for VMT per capita and VMT per employee at the regional average rather than 15-percent below the regional average. Implementing this change would bring the City’s VMT analysis methodology in line with the methodology of neighboring jurisdictions such as the City of San Bernardino, Riverside County, and the City of Jurupa Valley. 1 City of Riverside
VMT Mitigation Program
Introduction
California’s Senate Bill (SB) 743 is a legislative bill that alters the approach to reviewing transportation impacts under the California Environmental Quality Act (CEQA) for both land use projects, such as housing developments, and transportation improvements, such as road widenings. The bill shifts the focus away from congestion measures to vehicle miles traveled (VMT) generated by a project.

Prior to SB 743’s enactment, transportation impacts were evaluated based on Level of Service (LOS), a standard in the transportation sector since the first Highway Capacity Manual (HCM) was released in 1950.

LOS measures the driver’s experience in terms of delay or similar metrics and assigns a letter grade between “A” and “F” to suggest the need for further improvements. One of the unanticipated consequences of LOS, due to efforts to reduce delay and the cost of required transportation improvements resulting from new development, has been the construction of new housing and employment in less populated areas, leading to sprawl and greenfield development. Some transportation improvements aimed at improving LOS by reducing congestion have also resulted in a phenomenon called “induced demand,” wherein existing users begin making more trips due to the resulting reductions in travel time. Consequently, transportation improvements to accommodate growth have not always resulted in improved LOS, as the increase in existing user travel, along with accommodating anticipated travel from new development, has often left LOS no better than before the improvement. In addition to urban sprawl and induced demand challenges, LOS-influenced decision-making has led to other undesirable outcomes, including negative impacts on active transportation (bikes, pedestrians), public transit, and public health.

S B 7 4 3 a i m s t o r e v e r s e t h e s e t r e n d s b y a d o p t i n g V M T a s a m o r e h o l i s t i c m e a s u r e o f i m p a c t o n transportation systems. This shift from LOS to VMT encourages urban infill development, the use of active transportation and transit facilities, and reduces the environmental impacts associated with vehicular travel. Where VMT is typically lower, this approach seeks to promote sustainability and reduce greenhouse gas emissions. Exhibit 1 provides a summary of the differences between LOS and VMT.

Exhibit 1 – Level of Service vs. Vehicle Miles Traveled

2 City of Riverside
VMT Mitigation Program
With the change to VMT as the primary transportation performance metric, there has also been a need to identify new types of mitigations, as the solutions that work to address LOS impacts are often different from those that address VMT impacts. For instance, adding a new left-turn lane at an intersection to address a long delay adversely affecting LOS would not help address a VMT impact. Initially, most agencies across the state have relied on site-specific improvements, land use solutions, and transportation demand measures (TDM). However, in many instances, these solutions have not been sufficient to address significant transportation impacts for new projects.

Accordingly, there has been a growing interest in identifying new solutions to meet the increasing need for VMT mitigation. This study has been undertaken to evaluate the feasibility of a fee-based VMT mitigation program. Fee-based VMT mitigation programs seek to monetize VMT mitigation measures so that a project can obtain VMT mitigation proportional to its need. These programs have the potential to m a k e v a r i o u s V M T m i t i g a t i o n m e a s u r e s a v a i l a b l e t o p r o j e c t s t h a t w o u l d o t h e r w i s e n o t b e f e a s i b l e t o develop or could not otherwise obtain mitigation from. By monetizing the mitigation process, these programs aim to provide a more flexible and comprehensive approach to reducing vehicle miles traveled and promoting sustainable transportation development.

Major efforts undertaken by the study include:
· A literature review of VMT mitigation programs across California and relevant existing case law (Appendix B)
· An evaluation of the state of the practice for fee-based VMT mitigation programs (Appendix B) · Establishing the evaluation criteria for VMT reducing projects · Establishing the evaluation criteria for the VMT mitigation program · Conducting outreach to members of the Stakeholder Committee and the general public for input on the development of the City’s VMT mitigation program, which included soliciting VMT reducing mitigation measures for evaluation and inclusion in the City’s program (materials are found in Appendix C)
· Develop a tool to evaluate VMT impacts and mitigation measures (Appendix D) · VMT Mitigation Bank Program and CEQA Clearance white paper (Appendix E) · Developing a CEQA document (Categorical Exemption) to environmentally clear the City’s VMT mitigation program (Appendix F)
· Establishing the City’s VMT mitigation program
3 City of Riverside
VMT Mitigation Program
Existing City of Riverside SB 743 Policy
The City of Riverside’s Transportation Impact Analysis Guidelines 4 include policies for evaluating the transportation impacts of a land use project for both Level of Service (LOS) and Vehicle Miles Traveled (VMT). Specifically, for VMT and SB 743, the City’s Guidelines provide the methodology for assessing a development project’s VMT impact on the surrounding roadway network. The guidelines offer two methods for determining a development project’s impact:

1. Screening the project from a qualitative standpoint based on criteria that provide, assuming specific criteria are met, for a presumption of a less-than-significant transportation impact.

2. Using the RIVCOM travel demand model to quantitatively determine the project’s VMT efficiency or net change in regional VMT, as applicable. In lieu of the full application of the RIVCOM model, the City also allows for the use of the WRCOG online tool to evaluate impacts for applicable land use projects that are not of regional significance.

There are three types of screening criteria that the City uses to screen development projects from project- level analyses. The steps for the screening process includes:

1. Projects located in a Transit Priority Area (TPA)

2. Projects located in a low-VMT generating area

3. Project land uses presumed to have a less than significant impact absent substantial evidence to the contrary including the following:
o Local-serving retail projects less than 50,000 square-feet in size o Local-serving K-12 schools and day care centers
o Local parks
o Day care centers
o Local-serving gas stations, banks, hotels (e.g., non-destination hotels) o Student housing projects
o Local-serving community colleges consistent with the assumptions noted in the RTP/SCS o Projects consisting of 100% affordable housing
o Projects generating fewer than 110 daily vehicle trips

4. Projects located in Housing Element Opportunity Sites

5. Redevelopment Projects
If a development project cannot be screened from a quantitative analysis based on the above criteria, the project must be assessed using the RIVCOM travel demand model to determine whether the addition of the project results in a significant impact. A project would result in a significant project-generated VMT impact if the one of the following conditions are satisfied:
· For residential projects: the baseline or cumulative project-generated VMT per capita exceeds 15 percent below the current jurisdictional baseline VMT per capita. · For office and industrial projects: the baseline or cumulative project-generated VMT per employee exceeds 15 percent below the current jurisdictional baseline VMT per employee. · For new retail and other land use projects: the project results in an increase in regional VMT based on a threshold consistent with the net total VMT of the jurisdiction. 4 Traffic Impact Analysis Guidelines for Vehicle Miles Traveled and Level of Service Assessment. City of Riverside. July 2020. 4 City of Riverside
VMT Mitigation Program
T he Cit y of Rivers ide Guide lines a llow for a wide v ari et y of VMT mit igat ion. Howev er, m it ig at ing VMT impacts has proven to be more difficult than under the former LOS approach for analyzing traffic impacts.

As a practical matter, the new VMT methodology establishes a very restrictive approach to identifying transportation impacts both because of the basis for setting an impact threshold and limited mitigation opportunities. In terms of the threshold of significance, the City of Riverside recommends, consistent with state guidelines, that projects consisting of residential or general employment category land uses effectively need to be in an area where they are 15-percent less than the current jurisdictional baseline VMT efficiency for similar uses. This means that to avoid a VMT impact, new projects must be in an area where they are more efficient than similar uses from a VMT standpoint, otherwise they will have to identify enough mitigation to adequately address their impact. The need to identify additional mitigation options results in a growing need for feasible mitigation measures to address VMT impacts.

In terms of mitigation, the City of Riverside has relied on site-specific improvements, land use solutions, and transportation demand measures (TDM) to mitigate VMT impacts. The most recent version of the CAPCOA Guidebook 5 on mitigating VMT impacts is the primary resource available for evaluating the effectiveness of TDM mitigation measures in California. However, the CAPCOA guidebook is limited in its ability to reduce impacts within the City for several reasons, including:
· Many of the measures can be costly, particularly for smaller developments. · The context of a mitigation measure matters, and many TDM measures are most effective in dense urban areas.
· Many of the TDM measures are intended to be used by employers rather than for residential projects, and even ones that are able to be implemented by residential projects are still more effective for employment uses.
· The most effective TDM measures for residential projects are ones that can only be implemented via a significant program (very large developments).

Establishing a fee-based VMT mitigation program will allow the City of Riverside to do more to reduce VMT and its associated negative externalities by providing an additional funding mechanism for active transportation, transit, and other trip-reducing projects. Ideally, a fee-based VMT mitigation program does not discourage good design practices and instead is intended to meet VMT mitigation requirements that otherwise could not be met. Establishing the program will also have the added benefit of facilitating new development in the City and provide much-needed housing and other service needs. 5 Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity. California Air Pollution Control Officers Association (CAPCOA). December 2021. 5 City of Riverside
VMT Mitigation Program
Outreach Summary
A key component of the development of the City of Riverside’s VMT Mitigation Program was input from stakeholders and the public to help inform the selection of a recommended VMT program and its related VMT mitigation measures. At the onset of the study, an Outreach Plan was developed to serve as the basis for engaging and obtaining feedback from stakeholders and interested community members. The major components of the Outreach Plan included a Stakeholder Advisory Committee (SAC), targeted stakeholder outreach, a public meeting, a study website and online survey, social media posts, and branding. The Outreach Plan, summary memos of each meeting held, the presentation from each SAC meeting and the public meeting, and the online survey results can be found in Appendix B. Exhibit 2 below summarizes the key outreach efforts completed as a part of the study.

Exhibit 2 – Key Outreach Efforts Completed
Six SAC meetings were held throughout the lifecycle of the study. The SAC included a variety of individuals and organizations that represent the diverse nature of the City of Riverside both on the residential and business side of the City. As the VMT mitigation program would provide benefits to the entire City and provide feasible mitigation options to the business community looking to develop in the City, as varied a group as possible was solicited to participate. Those invited to participate in the SAC included:
· Neighborhood groups within the City of Riverside such as the Riverside Neighborhood Partnership, the Eastside Neighborhood Form, the Magnolia Area Neighborhood Alliance, and the University Neighborhood Association
· Business groups such as the Riverside Downtown Partnership, the County of Riverside Black Chamber of Commerce, the Riverside Chamber of Commerce, the Riverside Building Industry Association, and the Asian Business Association Inland Empire · Representatives of educational institutions, both K-12 and higher education institutions, such as the University of California Riverside, La Sierra University, Riverside Community College, and the Riverside Unified School District
· Local advocacy groups such as the Riverside Bike Club · Community Based Organizations (CBOs) such as the Latino Network

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In total, 45 different organizations were invited to participate in the SAC. The SAC meetings provided an opportunity to educate stakeholders, obtain input to inform study recommendations, and provide updates on the study's progress. The SAC’s input was solicited to inform both the selection of the recommended VMT mitigation program and its underlying VMT mitigation measures.

In addition to the six SAC meetings, the project team completed multiple targeted stakeholder meetings.

This included meetings with the Western Riverside Council of Governments (WRCOG), Riverside County, the Riverside Transit Authority (RTA), and the University of California at Riverside (UCR). These meetings provided an opportunity for these key agency partners to ask questions, provide recommendations, and suggest potential VMT mitigation measures.

One public meeting was held to solicit feedback on the study from members of the public with notices provided to the public in both English and Spanish. The public meeting took place at the Riverside Main Library on December 14, 2023, from 5:30 to 7:00 PM and Spanish speaking translators were available during the meeting. The meeting included a presentation by the project team and an open forum with boards showcasing the types of VMT-reducing mitigation measures being considered for the City’s VMT Mitigation Program and their respective locations throughout the City. Eight members of the public attended the meeting and were encouraged to ask questions about the program during the presentation.

The project team was also available to answer additional questions or discuss topics with the public after the presentation concluded.

In conjunction with the public meetings and the six SAC meetings, a dedicated project website was established at https://riversidevmt.com/. This website served as a central hub for information, allowing the public to stay informed about the program's developments, access meeting materials, and provide feedback. Exhibit 3 below is a screen capture of the project website.

Exhibit 3 – City of Riverside VMT Mitigation Program Project Website

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In addition to the project website, a public survey was drafted with a link posted on the website and distributed to the public via social media to solicit direct feedback on the study. Background information was provided along with the survey that included a short video on VMT and VMT mitigation programs.

The survey contained eight questions including the following:

1. Are you a Riverside resident, business owner, or both?

2. Have you heard of Vehicle Miles Traveled (VMT) before?

3. How do you feel about a fee program being introduced to provide additional options for development applicants to pay to reduce their Vehicle Miles Traveled (VMT) impacts?

4. Would you prefer a program where fees are charged based on the project size (e.g., number of dwelling units for residential project or total square-feet for non-residential projects) or by the size of their VMT impact (i.e., fees based on a project’s total VMT above the City’s threshold)? Note that in the first program type, fees are charged whether or not a project has a VMT environmental impact.

5. Which types of mitigation projects are you most excited about implementing? Please rank the following options: Transit, Bicycle/Pedestrian, Land use (affordable housing/transit-oriented development, Reduced demand (e.g., road diets, lane restrictions, and traffic calming), and Transportation Demand Management (e.g., telecommuting programs, carpooling programs, vanpool programs, or charging for on-street parking).

6. Which types of Transportation Demand Management measures do you prefer most to implement?

8. Concerns have been raised about implementing a fee-based VMT mitigation program. Please rank the concerns below from most concerning to least concerning in your option: Project selection (i.e., identifying feasible or cost-effective projects), Equity (i.e., ensuring the costs and benefits of a program are shared equally throughout the region), The potential for increasing the cost of development, Gathering enough community or decision-maker support to implement the program, and The potential legal issues or complexity of the program.

The results of the survey resulted in the following conclusions that heled shape the formation of the City’s VMT mitigation program:
· All respondents to the survey indicated that they were residents of the City · All but one respondent indicated that they would prefer a program where a portion of fees generated are required to be spent locally
· Few respondents indicated that they were familiar with VMT state requirements · 60-percent of respondents indicated that they do not support a developer fee program · 70-percent of respondents indicated they preferred a program in which fees are charged based on the size of a project’s impact
· Bicycle and transit improvements were the preferred types of mitigation measures · Telecommuting programs were the preferred types of transportation demand management measures by over 70-percent of respondents
· Identifying feasible or cost-effective mitigation measures for the program was the highest concern for the respondents while the potential legal issues or complexity of the program was the lowest concern
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To ensure wide-reaching engagement and accessibility, social media posts were crafted to spread awareness about the study and the public meetings. These posts were designed to reach a diverse range of individuals, drive interest, and encourage participation in the study.

The study also established branding for the program consistent with other existing City of Riverside programs. With input from City staff and the SAC, the logo in Exhibit 4 was established for use in future efforts surrounding branding of a fee-based VMT mitigation program.

Exhibit 4 – City of Riverside VMT Mitigation Program Logo

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Establishing Mitigation Need
Future development locations, development quantity, and the corresponding mitigation requirements play a crucial role in assessing the necessity of a fee-based VMT mitigation program and its potential scope. To accomplish this, a dataset was created by utilizing data from the RIVCOM travel demand model.

This dataset estimates the VMT mitigation needs for the City. This data analysis assisted in evaluating the overall feasibility of different program options and determining the scale of VMT mitigation measures that would be needed to mitigate the City’s VMT. This dataset holds significance in understanding the potential cost magnitude that individual development projects may need to bear to fully mitigate their VMT impacts. It also provides insights into how these costs may influence policy considerations concerning the definition of feasible mitigation under CEQA.

B y l e v e r a g i n g t h e R I V C O M m o d e l a n d u s i n g t h e C i t y ’ s V M T t h r e s h o l d s , t h e t o t a l p o t e n t i a l V M T t o b e mitigated was determined by calculating the difference between the VMT per capita and VMT per employee for each Traffic Analysis Zone (TAZ) that was over the established thresholds. The difference was then multiplied by the population and total employees for each TAZ to develop a total VMT per TAZ to be mitigated, which then allowed for a citywide total to be calculated.

Based on the analysis, it is anticipated that based on the households and jobs that will be constructed or created between 2018 and 2045 in locations that are currently above the City’s VMT threshold, the total VMT needing to be mitigated is 191,803 VMT for residential land uses and 299,003 VMT for employment land uses. This equates to a mitigation need of 7,104 VMT per year for residential land uses and 11,074 VMT per year for the employment land uses for the 27-year period between 2018 and 2045, as shown in Table 1.

Table 1 – Potential Land Use Growth and VMT to Mitigate, 2018 to 2045 Community Type
Future VMT to Mitigate
Residential Employment Total
Total VMT (Thru 2045) 191,803 299,003 490,806
Total VMT per Year 7,104 11,074 18,178
Exhibit 5 and Exhibit 6 v i s u a l l y s h o w t o t a l V M T n e e d i n g t o b e m i t i g a t e d b y 2 0 4 5 f o r r e s i d e n t i a l a n d employment land uses.
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Exhibit 5 – Residential VMT Mitigation Need by TAZ
Exhibit 6 – Employment VMT Mitigation Need by TAZ

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VMT Evaluation Tool
As part of this study, the project team developed an online VMT evaluation tool, an application designed to estimate the VMT impact of development projects. The use of sketch models, or VMT estimation tools to conduct SB 743 compliant evaluation of VMT impacts and mitigation evaluation is a well-established practice in many locations throughout California. In OPR’s 2018 guidance documentation 6 evaluating CEQA transportation impacts under SB 743, it specifically states “Travel demand models, sketch models, spreadsheet models, research, and data can all be used to calculate and estimate VMT…”. This tool enables the user (City staff or others that staff deems appropriate to use the tool) to select parcels corresponding to the location of a proposed project, input specific project information, and execute the evaluation process. The tool then performs detailed VMT calculations, providing the user with impact results including total VMT generated, VMT per capita, VMT per employee, the VMT per unit threshold specific to the relevant agency in which the project is located, the percentage by which the development project exceeds or falls below this threshold, supplementary data including planning level estimates of greenhouse gas emissions associated with the implementation of the project, and options to mitigate identified VMT impacts.

A beta version of the VMT estimation tool, based on the project team’s TREDLite VMT product, along with a user guide (provided in Appendix D), was presented to the SAC. During the presentation to the SAC, the VMT estimation was tested with multiple example development projects, providing a practical demonstration of its capabilities.
6 California Governor’s Office of Planning and Research (OPR). (2018). Technical Advisory on Evaluating Transportation Impacts in CEQA, Page 30
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VMT Mitigation Measures
Various VMT mitigation measures are available for projects that need to reduce their VMT impacts.Exhibit 7 below highlights examples of measures that can reduce VMT in the City. As shown, there are a variety of VMT mitigation measures that can be used to mitigate project VMT impacts. However, it can be difficult for a single project applicant to implement these VMT mitigation measures for a variety of reasons, including:

1. Legal Jurisdiction
· Issue: Many VMT mitigation measures fall under the jurisdiction of the City, which must sponsor, fund, and oversee their implementation.
· Solution: City-led initiatives with clear roles and responsibilities for project sponsors.

2. Cost Prohibitive Nature
· Issue: High costs associated with VMT mitigation measures may be unaffordable for individual applicants, and coordination among multiple applicants for joint funding is complex. · Solution: Establish a fee-based VMT mitigation program managed by the City to pool resources and fund large-scale VMT reduction projects.

3. Management and Construction Capabilities
· Issue: Individual applicants often lack the expertise to manage and construct public works improvements, especially those involving complex policy and planning elements. · Solution: Centralized management by the City to ensure proper implementation and oversight of VMT mitigation measures.

Given these challenges, it is not practical for individual project applicants to undertake many VMT mitigation measures alone. A City-led, fee-based VMT mitigation program is necessary to facilitate the implementation of these mitigation measures, leveraging the City's legal jurisdiction, financial resources, and technical expertise to achieve the desired VMT reductions comprehensively. 13 City of Riverside
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Exhibit 7 – VMT Mitigation Measures
Prior to choosing mitigation measures for evaluation, the measures must first meet the criteria of additionality, a requirement set by CEQA where the need for mitigation must be caused by a project impact. In addition, Caltrans defines additionality as “a critical step in asserting such mitigation is to assure that the investment provides additional resources that otherwise would not have been provided or providing the additional resources substantially earlier than they otherwise would have been available.” Put simply, a mitigation measure would not have happened were it not for the additional funding from the fee-based VMT mitigation program.

Once it was determined which mitigation measures meet the criteria of additionality, mitigation measures were selected for further evaluation based on the following considerations:

1. High non-single occupancy or active transportation trip rate potential : improvements with higher usage (i.e., high bike ridership).

2. Located in a denser area: mitigation measures located in existing infill areas are favorable.

3. Shorter trip lengths: shorter trips tend to favor active transportation and transit usage.

4. Financial need : the mitigation measure has financial need sufficient to meet additionality requirements. Note that this can also be accomplished by advancing a mitigation measure that would not otherwise be constructed in the near term.

5. Measure feasibility: other than financial needs, the measure is likely to be constructed in the near term.

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Once VMT mitigation measures were chosen for evaluation, the measures were ranked according to criteria summarized in Exhibit 8.

Exhibit 8 – VMT Mitigation Measure Ranking Criteria
Caltrans has also provided some additional clarity on the claiming of VMT mitigation for mitigation measures that are only partially funded by a fee-based VMT mitigation program. Its most recent guidance7, suggests that a fee-based VMT mitigation program does not need to be the sole funder to claim the full mitigation credit. This applies to models like in-lieu fee payments or mitigation programs where the sponsor transacts with another party for mitigation. According to Caltrans, as long as the mitigation is enforceable, feasible, not deferred, and mechanisms are in place to avoid double counting, a sponsor can claim full mitigation credit.

This interpretation allows the City of Riverside to calculate the unit cost per VMT for VMT-reducing measures by dividing the proportional cost by the full VMT credit. If the funding from a fee-based VMT mitigation program does not fully cover the project, additional funding must be secured. This approach enables the inclusion of a wide array of VMT-reducing measures in the program but could pose difficulties securing extra funding to fill any financial shortfall if the program does not fully fund the mitigation measure.

Fee-Based VMT Mitigation Program Framework Options
T o b r o a d e n t h e s c o p e o f V M T m i t i g a t i o n o p t i o n s , V M T m i t i g a t i o n p r o g r a m s , l i k e t h o s e u n d e r consideration in this study, are being explored for implementation across California. These programs have the potential to provide a range of land use and transportation projects, irrespective of size or type, with the ability to participate in VMT mitigation measures at a level commensurate with their impact.

Exhibit 9 visually illustrates the process of mitigating transportation impacts in areas with a fee-based VMT mitigation program. As shown, fee-based VMT mitigation programs are typically intended to be secondary to site-specific improvements, land use solutions, and transportation demand measures (TDM) 7 Caltrans, Housing and VMT Mitigationhttps://dot.ca.gov/programs/esta/sb-743/resources/housing, accessed on 3/6/2024

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that may be implemented by a project applicant. As noted previously, a fee-based VMT mitigation program ideally does not discourage good design practices and instead is intended to meet VMT mitigation requirements that otherwise could not be met.

In the example project from Exhibit 9, the initial calculation shows that the project exceeds its VMT threshold by 450 VMT, with a threshold set at 4,550 VMT and an initial project generated VMT of 5,000 VMT. To address this excess, the project implements various on-site TDM measures, successfully reducing the VMT by 225 VMT, thereby lowering the excess VMT to 225 VMT (from the initial 450 VMT). To further mitigate this remaining VMT, the project pays into a fee-based VMT mitigation program, thus reducing the final 225 VMT. This combination of on-site TDM measures and contributions to a fee program ensures that the project complies with the VMT threshold requirements resulting in a project’s transportation impact being fully mitigated.

Exhibit 9 – Application of a VMT Mitigation Program
Although fee-based VMT mitigation programs can take multiple forms, the three most common program types, and the primary focus of this study, are discussed below.

VMT Bank
A VMT mitigation bank is a structured program designed to help project applicants offset their VMT i m p a c t s b y p u r c h a s i n g c r e d i t s f r o m a c e n t r a l r e p o s i t o r y o f V M T m i t i g a t i o n m e a s u r e s . I n t h e C i t y o f Riverside, the VMT bank would function as a central entity collecting fees from project applicants whose projects have a significant transportation impact as defined by the City’s CEQA guidance and have not otherwise implemented sufficient VMT mitigation measures. These funds would be used by the City to implement various VMT mitigation measures across Riverside.

Managed by the City, the VMT bank ensures efficient and effective planning, funding, and implementation of VMT mitigation measures. When a new development project is proposed, its expected VMT impact is assessed, and the project applicant would pay a fee to the VMT mitigation bank based on the extent of the VMT impact that needs to be offset, considering other VMT mitigation measures the applicant may

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have implemented. Collected funds are allocated to pre-approved mitigation measures, chosen for their potential to reduce VMT and align with existing City transportation goals. The VMT bank oversees the implementation and monitoring of these mitigation measures to ensure their effectiveness. The VMT mitigation bank offers developers flexibility and a simplified compliance process, providing a straightforward fee payment to meet VMT mitigation requirements while achieving significant overall VMT reductions.

To establish a VMT mitigation bank, the following steps are undertaken, as shown in Exhibit 10:

1. Identify VMT-reducing mitigation measures, such as bicycling facilities, pedestrian infrastructure, and public transit.

2. Evaluate these mitigation measures to determine the extent of VMT reduction.

3. Combine the VMT reductions from all mitigation measures to calculate the total mitigated VMT (e.g., 1,000 VMT).

4. Sum the costs associated with all mitigation measures (e.g., $1 million).

5. Calculate the cost per VMT reduced by dividing the total mitigation measure cost by the total VMT reduction (e.g., $1,000 per VMT).

Once the cost per VMT is established and the VMT bank is operational, a project can offset its VMT impact by paying a per VMT fee to the bank. For instance, if a project needs to reduce its VMT impact by 225 VMT to meet the City’s VMT threshold requirements, the total fee would be $225,000, calculated by multiplying the cost per VMT reduced ($1,000/VMT) by the total VMT needing to be reduced (225 VMT). Once the available VMT is used up by development projects purchasing VMT from the bank, new VMT mitigation measures would need to be identified to replenish the VMT bank.

Exhibit 10 – VMT Bank Example

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VMT Exchange
VMT exchanges function similarly to VMT banks, with the primary difference being that in a typical VMT exchange, project applicants have the flexibility to select a single VMT mitigation measure from an existing list or program of VMT mitigation measures or propose a new VMT mitigation measure that may not be listed. Unlike VMT banks, it is not necessary to monetize the selected VMT mitigation measure unless the project applicant wishes to make excess VMT mitigation available to others for purchase as credits.

For instance, as illustrated in Exhibit 11, an applicant develops a bicycle improvement that reduces VMT by 300 VMT. However, if the applicant only needs to reduce their VMT impact to the VMT threshold by 225 VMT, they would have 75 surplus VMT available to sell to others at a market rate. The market rate can be determined by the City to be based on the cost per VMT reduced of the measure constructed/implemented by the applicant or based on the demand for that VMT from other project applicants. This flexibility allows project applicants to directly contribute to the City’s ability to offer VMT mitigation while also potentially benefiting financially from their excess VMT mitigation credits. The VMT exchange model provides a dynamic and flexible approach to VMT mitigation, enabling tailored solutions and encouraging innovative VMT-reducing mitigation measures.

Exhibit 11 – VMT Exchange Example
VMT Impact Fee
Under a VMT Impact Fee program, a new development project would be required to pay a fee to offset its VMT impact, determined by factors such as the total number of planned dwelling units or the total square footage of planned building construction. This program would function similarly to existing development fee programs but would exclusively fund mitigation measures that reduce VMT. Notably, if an applicant project is located in an area that does not result in a significant transportation impact as defined by the City’s VMT guidance, it would not incur a fee.

As illustrated in Exhibit 12 , the fees are calculated by land use types based on the projected VMT generation from planned developments over a 10-20 year timeframe, focusing on offsetting the VMT mitigation requirement. Like the VMT bank, fees are computed by dividing the total VMT needed to be

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mitigated by future projects by the cumulative cost of VMT mitigation measures. However, unlike a VMT bank, this calculation is performed separately for each land use type rather than being assigned to projects based on their unique VMT mitigation requirements.

The fee for each land use type is determined by first quantifying the VMT that needs to be mitigated for each land use type, calculating the share of the total VMT requiring mitigation, multiplying that percentage share by the total cost of the VMT-reducing mitigation measures, and then dividing the land- use specific cost by the growth for each land use (either dwelling units or square feet). For example, if the residential land use accounts for 50-percent of all future VMT mitigation needs and the total cost of VMT- reducing mitigation measures is $1 million, then the residential land use would have a total mitigation cost of $500,000 (50-percent of $1 million). If the anticipated number of houses to be constructed in the future is 250 houses, the fee would be calculated by dividing $500,000 by 250 homes, resulting in a fee of $2,000 per home.

This fee-based VMT mitigation program would streamline the process for developers by providing a clear and predictable cost structure while ensuring that funds are directed toward effective VMT-reducing mitigation measures. By aligning the fees with specific land use types and their associated VMT impacts, the program ensures that mitigation efforts are proportionate and targeted, ultimately contributing to the reduction of overall VMT in the City.

Exhibit 12 – VMT Impact Fee Example
If implemented, to enhance the effectiveness of a VMT impact fee framework, it would be beneficial to divide the City into multiple benefit areas. This allows for fees to be assessed based on the VMT efficiency of a benefit zone in terms of overall VMT performance. Such an approach can incentivize projects to locate in VMT-efficient areas within the City.

As shown in Exhibit 13, the areas forming Zone 1 all fall below the VMT threshold for both residential and non-residential uses, resulting in no fees being administered for projects in that zone. Conversely, Zone 2 has the worst VMT performance and thus contains the highest fees charged for the City. This zonal approach ensures that the VMT impact fee framework not only promotes development in areas with

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lower VMT but also directs mitigation efforts and funds toward areas with higher VMT impacts, thereby optimizing the overall reduction in VMT across the City.

Exhibit 13 – VMT Impact Fee Program with Multiple Benefit Areas

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Program Evaluation
Exhibit 14 below provides a summary of how each type of VMT mitigation program was evaluated against the six program evaluation criteria established during the study. White dots indicate a “concern” that the complexity of a specific program criterion or the lack of practical experience with it may represent a challenge to its implementation. While all program types are believed to be ultimately implementable, these designations highlight areas that will require additional evaluation before their respective programs can be considered for implementation. Following is a description of the program evaluation criteria:
· Legal – The program meets CEQA and statutory requirements including additionality. · Effective – The program has potential to achieve significant VMT reductions. · Geography – The program is able to scale to meet the City’s needs. · Administration – The program is able to fund oversight and management of the program, including technical analyses.
· Equitable – The program avoids disproportionate impacts and encourages equitably distributing benefits.
· Alignment – The program aligns with community values and plans and supports good project design.
· Timeliness – T h e p r o g r a m i n c l u d e s m i t i g a t i o n m e a s u r e s t h a t c a n b e i m p l e m e n t e d i n a t i m e l y manner.
· Feasibility – The program includes mitigation measures that do not have major obstacles to implementation.

As shown in Exhibit 14, only the VMT bank framework does not have any concerns for the designated evaluation criteria.

Exhibit 14 – VMT Mitigation Program Evaluation
The VMT mitigation exchange option could raise concerns about nexus and proportionality if a project applicant undertakes mitigation measures that are disproportionate to the VMT impact being mitigated

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and is subsequently unable to sell their excess VMT mitigation at market value. Additionally, administering a program where unknown mitigation measures are proposed raises questions about the predictability of VMT mitigation measure availability to the City. Since a VMT exchange allows for mitigation measures that may not otherwise be considered by the City, there are questions regarding whether the proposed mitigation measures would align with the City’s goals as established in its existing plans. Lastly, such mitigation measures could be implemented indiscriminately around the City and/or with a bias towards certain areas, raising concerns about the equitable distribution of mitigation measures.

While a VMT mitigation impact fee address some of the concerns raised by the VMT exchange model, it is fixed with regard to geographic implementation and does not allow for as much flexibility to respond to development mitigation needs. Most concerning is that an individual project applicant would not get credit for mitigation measures implemented on-site, and as such, a VMT impact fee program would not necessarily incentivize good design choices. The way impact fees are calculated also adds more complexity to their administration, and impact fee programs must comply with numerous state laws, requiring more staff time from the City compared to other program options.

After discussions with the Stakeholder Committee, it was decided that any program with a VMT exchange should be removed due to these concerns and that an impact fee approach was not a good fit for the City g i v e n i t s c o m p l e x i t y t o a d m i n i s t e r . T h i s l e f t t h e V M T b a n k i n g o p t i o n a s t h e o n l y f r a m e w o r k f o r consideration that was not associated with any major obstacles or concerns. Ultimately, it was the rec ommendat ion of t he St akeholder Commit t ee , Cit y st aff, and t he projec t t eam t hat a VMT bank be considered as the preferred framework for the City’s future program to reduce complexity and address concerns around equity by the public agencies implementing the program. 22 City of Riverside
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Identifying and Evaluating VMT Mitigation Measures
This study analyzed the specific mitigation measures that could be included in the City’s fee-based VMT mitigation program. The initial phase involved the identification of mitigation measure categories that would undergo review before individual mitigation measures were selected for evaluation. These categories included active transportation (bicycle and pedestrian), transit, transportation demand measures, land use (affordable housing), and others.

Understanding a need for a diverse set of mitigation measures, both in terms of geographic location as well as mitigation measure type, several different sources were used to develop potential mitigation measures. Potential mitigation measures were solicited from the SAC during the third meeting with the Stakeholders, existing City plans and documents, and four one-on-one agency meetings with WRCOG, Riverside County, RTA, and UCR.

Below is a description of the methodology used to evaluate each mitigation measure type, as well as a summary of the evaluation results for each mitigation measure.

Bicycle Mitigation Measures Evaluation
Twenty-nine bicycle improvements located throughout the City were evaluated to determine their feasibility for inclusion in the City’s fee-based VMT mitigation program. These improvements were s o u r c e d f r o m t h e R i v e r s i d e P A C T8, which includes the City’s Bicycle Master Plan 9, and the Northside Specific Plan10. Note that several improvements listed in the PACT were identified for evaluation but were subsequently noted as being constructed or otherwise funded and were removed from consideration. In addition, modifications have been made to the extents of the improvements based on improvements since the City’s Bicycle Master Plan has been published.

The approach to calculate VMT reductions for bicycle mitigation measures involved a multi-step process that integrates various data inputs and modeling techniques. The approach used in this study to analyze bicycle improvements includes:
· Estimates for future ridership were based on the National Cooperative Highway Research Program (NCHRP) 55211 methodology
· Transportation analytics data (Replica) was used to determine the average trip distance along the improvement’s alignment
· To better isolate the effects of the mitigation measures, the change in VMT was calculated for areas within 0.5, 1.0, and 1.5 miles of the improvement 8 The City of Riverside PACT: Pedestrian Target Safeguarding Plan (PTS), Active Transportation Plan (AT Plan), a Complete Streets Ordinance (CSO), and a Trails Master Plan (TMP). City of Riverside. https://riversideca.gov/pact. 9 City of Riverside Bicycle Master Plan. City of Riverside and Alta Planning + Design. Adopted May 22, 2007. 10 Northside Neighborhood & Pellissier Ranch Specific Plan. City of Riverside. Adopted November 17, 2020. 11 NCHRP Report 552, produced under the auspices of the Transportation Research Board (TRB), offers a framework for evaluating bicycle infrastructure investments, guiding planners in assessing economic, social, and environmental impacts. It provides methods to quantify benefits like accessibility, reduced congestion, health, and environmental gains, supporting informed decisions on bike facilities. The NCHRP itself is a program funded by member states of the American Association of State Highway and Transportation Officials (AASHTO), in cooperation with the Federal Highway Administration (FHWA). 23 City of Riverside
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· Transportation analytics was also used to calibrate bicycle ridership levels along the recommended alignment using existing mode split and bicycle ridership along the improvement’s alignment
· The number of trips generated by the implementation of the improvement were further filtered to remove trips not associated with replacing vehicle trips such as exercise trips · The factored ridership was multiplied by the average trip distance to determine the total VMT reduced by implementation of the improvement
The results of the VMT reduction analysis for the VMT mitigation measures are summarized in Table 2 below with costs per VMT reduced ranging from $10 to $32,827. The costs for each project shown inTable 2 were obtained from the source documents such as the Riverside PACT’s Active Transportation Plan8 and detailed cost estimates developed by the City.

The types of bicycle improvements evaluated included a bike path (Class I), bike lanes (Class II), buffered bike lanes (Class IIB), bicycle routes (Class III), bicycle boulevards (Class IIIB), and separated bikeways (Class IV). Exhibit 15 below provides an illustrative example of the types of bicycle improvements evaluated as a part of this study.

Exhibit 15 – Types of Bicycle Improvements Evaluated for the City of Riverside Table 2 – Summary of Bike Mitigation Measure Evaluation Project
ID
Roadway Ward Description Cost VMT
Reduced Cost/VMT
1 Dufferin Avenue* 5 Stripe bicycle boulevard between
Van Buren Blvd and Jefferson St $ 4,672,260 142 $32,827 2 Victoria Avenue* 3,4,5
Construct buffered bike lane
between Washington St and Central
Ave
$4,900,730 251 $19,556
3 14th Street* 2 Stripe buffered bike lane between
Chicago Ave and Brockton Ave $1,132,716 102 $11,075
4 Gramercy Place* 6,7 Stripe bike lane between La Sierra Ave and Tyler St $1,048,552 115 $9,101
5 Gramercy Place* 7 Stripe bicycle route between Tyler St and Crest Ave $527,763 78 $6,766

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Project
ID
Roadway Ward Description Cost VMT
Reduced Cost/VMT
6 Streeter Avenue* 3
Construct buffered bike lane
between Arlington Ave and Jurupa
Ave
$1,752,162 281 $6,246
7 Hole Avenue* 6 Construct buffered bike lane
between Wells Ave and Collett Ave $1,123,805 195 $5,755 8 Madison Street* 3,4
Stripe bike lane, buffered bike lane,
and bike boulevard between Indiana
Ave and Victoria Ave
$627,192 131 $4,792
9 Maude Street* 3 Stripe bicycle boulevard between
Victoria Ave and Arlington Ave $1,215,000 305 $3,989
10 Kansas Avenue* 2 Stripe bicycle boulevard between
University Ave and 3rd St $1,516,086 386 $3,931
11 Jurupa Avenue* 3
Construct buffered bike lane
between Van Buren Blvd and
Wilderness Ave
$1,248,773 326 $3,834
12 Lemon Street* 1 Construct separated bikeway
between 14th St and 3rd St $1,912,658 636 $3,009
13 Arlington Avenue* 3 Stripe bike lane between Indiana Ave and Magnolia Ave $1,174,689 432 $2,719
14 Columbia
Avenue*** 1 Stripe bike lane between American
Dr and Salmon River Rd $41,719 90 $462
15 Cypress Avenue** 6,7 Stripe bike lane between La Sierra Ave and Crest Ave $38,800 145 $267
16 Orange Street*** 1 Construct separated bikeway
between 14th St and 3rd St $176,239 733 $240
17 Hole Avenue** 6 Stripe buffered bike lane between
Collett Ave and Magnolia Ave $ 63,360 322 $197
18 Tyler Street** 6,7 Stripe bike lane between Diana Ave and Arlington Ave $110,000 571 $193
19 University
Avenue*** 2 Construct a buffered bike lane
between Iowa Ave and Campus Dr $133,358 750 $178
20 Jackson Street** 5 Construct bike path between Diana Ave and Magnolia Ave $54,600 310 $176
21 Adams Street** 5 Strip buffered bike lane between
Diana Ave and Arlington Ave $83,200 738 $113
25 City of Riverside
VMT Mitigation Program
Project
ID
Roadway Ward Description Cost VMT
Reduced Cost/VMT
22 Brockton Avenue* 3 Stripe bike lane between Magnolia Ave and Beatty Dr $62,605 593 $106
23 California
Avenue** 5 Stripe buffered bike lane between
Van Buren Blvd and Adams St $76,800 801 $96
24 Van Buren
Boulevard** 5,6 Stripe buffered bike lane between SR
91 and Arlington Ave $161,600 1,904 $85
25 Monroe Street** 5 Stripe buffered bike lane between
Diana Ave and Arlington Ave $90,400 1,308 $69
26 Gramercy Place** 6 Strip bike boulevard between Crest Ave and Rutland Ave $4,400 129 $34
27 Colorado
Avenue** 5 Stripe bike boulevard between Van
Buren Blvd and Adams St $25,944 1,606 $16
28 Rutland Avenue** 6 Stripe bike boulevard between Wells Ave and Arlington Ave $15,072 1,058 $14
29 Wells Avenue** 6 Stripe bicycle route between Tyler St and Crest Ave $5,960 614 $10
Improvements denoted with a single asterisk (*) had their costs taken directly from the Riverside PACT’s Active Transportation Plan8, improvements denoted with two asterisks (**) had their costs developed by City staff as part of the City’s fiscal year 2024 Safe Streets for All (SS4A) Grant applications 12, and improvements denoted with three asterisks (***) had their costs estimated using the average cost per mile per facility type (e.g., buffered bike lane or bike boulevard) developed during the 2024 SS4A Grant applications. In addition, for the twelve improvements for which the City was awarded an SS4A Grant, the g r a n t w i l l c o v e r 8 0 - p e r c e n t o f t h e t o t a l p r o j e c t c o s t , w i t h t h e C i t y r e s p o n s i b l e f o r t h e r e m a i n i n g 2 0 - percent. Since the City has not yet allocated funds for these improvements (the grant application indicated that the funding source was to be determined), incorporating these improvements into the City’s program at the City's responsibility level of 20-percent complies with the previously discussed additionality requirement.

After evaluating the 29 bicycle improvements using the methodology outlined above, 16 were identified as result ing in a c ost per VMT reduc ed less t han $2,000. Exhibit 16 visually shows t he loc at ion of t he sixteen bicycle improvements recommended for inclusion in the City’s program whileTable 3 summarizes the change in VMT for the sixteen bicycle improvements selected. Note that due to high costs per VMT reduced for individual improvements, the sixteen improvements selected do not include improvements in Ward 4.
12 Safe Streets and Roads for All (SS4A) Program. California Department of Transportation (Caltrans). Fiscal Year (FY) 2024. https://dot.ca.gov/programs/local-assistance/fed-and-state-programs/safe-streets-and-roads. Accessed October 15, 2024. 26 City of Riverside
VMT Mitigation Program
The bike improvements along Wells Avenue, Rutland Avenue, and Colorado Avenue stand out as the most cost-effective, with all three having a cost per VMT reduced between $10 and $16, reducing a total of 3,278 VMT daily.

Exhibit 16 – Location of Bicycle Improvements Resulting in a Cost Less than $2,000/VMT Reduced Table 3 – Bike Mitigation Measures with Cost/VMT Reduced less than $2,000 Project
ID Roadway Ward Description Cost VMT
Reduced Cost/VMT
14 Columbia Avenue 1 Stripe bike lane between
American Dr and Salmon River Rd $41,719 90 $462
15 Cypress Avenue 6,7 Stripe bike lane between La
Sierra Ave and Crest Ave $38,800 145 $267
16 Orange Street 1 Construct separated bikeway
between 14th St and 3rd St $176,239 733 $240
17 Hole Avenue 6
Stripe buffered bike lane
between Collett Ave and
Magnolia Ave
$ 63,360 322 $197

27 City of Riverside
VMT Mitigation Program
Project
ID Roadway Ward Description Cost VMT
Reduced Cost/VMT
18 Tyler Street 6,7 Stripe bike lane between Diana
Ave and Arlington Ave $110,000 571 $193
19 University Avenue 2
Construct a buffered bike lane
between Iowa Ave and Campus
Dr
$133,358 750 $178
20 Jackson Street 5 Construct bike path between
Diana Ave and Magnolia Ave $54,600 310 $176
21 Adams Street 5 Strip buffered bike lane between
Diana Ave and Arlington Ave $83,200 738 $113
22 Brockton Avenue 3 Stripe bike lane between
Magnolia Ave and Beatty Dr $62,605 593 $106
23 California Avenue 5
Stripe buffered bike lane
between Van Buren Blvd and
Adams St
$76,800 801 $96
24 Van Buren
Boulevard 5,6 Stripe buffered bike lane
between SR 91 and Arlington Ave $161,600 1,904 $85
25 Monroe Street 5
Stripe buffered bike lane
between Diana Ave and Arlington
Ave
$90,400 1,308 $69
26 Gramercy Place 6 Strip bike boulevard between
Crest Ave and Rutland Ave $4,400 129 $34
27 Colorado Avenue 5 Stripe bike boulevard between
Van Buren Blvd and Adams St $25,944 1,606 $16
28 Rutland Avenue 6 Stripe bike boulevard between
Wells Ave and Arlington Ave $15,072 1,058 $14
29 Wells Avenue 6 Stripe bicycle route between
Tyler St and Crest Ave $5,960 614 $10
Pedestrian Mitigation Measure Evaluation
Pedestrian mitigation measures can be challenging to include in a fee-based VMT mitigation program given t hat t he vehic le t rips t hat t hey replac e are t ypic ally very short , t hus li mit in g t heir effec t iveness .

Further complicating the evaluation is that a large majority of the improvements considered, including those included in the Riverside PACT, are improvements at intersections rather than along corridors.

Pedestrian improvements included in the Northside Specific Plan and the City’s Local Roadway Safety Plan13 ( L R S P ) w e r e a l s o r e v i e w e d , b u t d u e t o a n e s t i m a t e o f a c o s t a b o v e $ 1 m i l l i o n , a n d / o r a V M T reduction of less than 50 VMT, were deemed infeasible. Note that similar to the bicycle improvements, pedestrian improvements that were identified in either document, but have since been constructed or otherwise funded were removed from consideration.
13 City of Riverside Local Roadway Safety Plan. City of Riverside. 2022. 28 City of Riverside
VMT Mitigation Program
Intersection improvements don’t typically result in a decrease in vehicle trips unless they are combined with improvements along the corridors to ensure that walking is a viable replacement to driving. Thus, while eleven pedestrian mitigation measures were identified for further evaluation (five from the R i v e r s i d e P A C T , f i v e f r o m t h e N o r t h s i d e S p e c i f i c P l a n , a n d o n e f r o m t h e C i t y ’ s L R S P ) , n o n e o f t h e improvements were identified as being viable for inclusion in the City’s VMT mitigation program due to their high cost and low VMT reduction. The thirteen projects considered are summarized inTable 4 below.

Table 4 – Summary of Pedestrian Mitigation Measures Considered for Evaluation Project ID Roadway Description Cost Distance
30 Main St Complete street improvement with two 5 - 8-foot sidewalks between Columbia Ave and Garner Rd ≥ $1 Million 0.56 31 Main St
Complete street improvement with 5 - 8-foot
sidewalk between Columbia Ave and the Santa Ana
River
≥ $1 Million 0.63
32 Center St Complete street improvements between
Main St and I-215 ≥ $1 Million 1.2
33 Columbia Ave Complete street improvement with 5 - 9-foot sidewalk between Main St and Orange St ≥ $1 Million 0.38 34 Orange St Complete street improvement with 5.5-foot
sidewalk between SR-60 and Center St ≥ $1 Million 1.12
35 Iowa Ave
Improve intersection at W Linden St using high
visibility crosswalks, leading pedestrian intervals,
pedestrian scrambles, advance limit lines, and/or
restricting right turns on red
$620,000 -
36 Jurupa Ave Add leading pedestrian interval at intersection with Magnolia Ave $85,000 -
37 Wood Rd
Improve intersection with Van Buren Blvd using
curb extensions, restricting right turns on red, high
visibility crosswalks, and/or adding a pedestrian
scramble
$447,000 -
38 Indiana Ave
Improve intersection with La Sierra Ave by adding
leading pedestrian interval and other
improvements such as adding curb ramps or
restricting right turns on red
$590,000 -
39 Western Ave
Improve intersection with Arlington Ave by adding
leading pedestrian interval and other
improvements such as adding curb ramps or
advance limit lines
$205,250 -
40 14th St Install leading pedestrian interval at intersection with Olivewood Ave $50,000 -
29 City of Riverside
VMT Mitigation Program
Table 5 below provides a summary of four pedestrian mitigation measures that were evaluated to show the difficulty in including them within a fee-based VMT mitigation program. The VMT reduction was determined based on the number of vehicle trips estimated to be removed based on the existing pedestrian mode share within the City of Riverside, as well as the average pedestrian trip distance, obtained from Replica as 0.6-miles. As shown in Table 5, the cost per VMT reduced ranged between $41,667 and $120,370 per VMT reduced. When compared to limit of $2,000 per VMT threshold used for the bicycle improvements evaluated, the pedestrian improvements far exceeded this value. Note that while pedestrian mitigation measures are not well suited for a fee-based VMT mitigation program due to the low amount of VMT reduced for the cost to construct, they should continue to be prioritized for implementation because they confer a host of other benefits outside of VMT reduction such as increased safety for people walking along roadways.

Table 5 – Summary of Pedestrian Mitigation Measure Evaluation Project ID Roadway Description Cost VMT
Reduced Cost/VMT
34 Orange St Complete street improvement with 5.5-foot
sidewalk between SR-60 and Center St $1,000,000 24 $41,667 31 Main St
Complete street improvement with 5 - 8-
foot sidewalk between Columbia Ave and
the Santa Ana River
$1,000,000 30 $33,333
33 Columbia Ave
Complete street improvement with 5 - 9-
foot sidewalk between Main St and Orange
St
$1,000,000 45 $22,222
Transit Mitigation Measure Evaluation
Transit mitigation measures can provide a large reduction in VMT as they can move large numbers of riders from their homes to non-residential locations such as places of employment or shopping and eating establishments. These mitigation measures can include brand new transit routes to connect different locations within the City that are not currently served by a transit service or can include additional buses along existing routes to reduce headways and provide reliable alternatives to driving. Transit mitigation measures can be costly, particularly if they include the capital costs required to purchase a new bus and the operating costs to pay a driver over a long time period. So, while transit improvements can provide some of the largest amounts of VMT reduction, their cost per VMT reduced is not always attractive without including other funding sources.

The methodology used to calculate VMT reductions for transit mitigation measures consider for inclusion in the City’s program includes the following:
· The BRT Practitioner’s Guide 14 was used to determine ridership increases based on headway reductions
o The existing ridership was estimated based on data obtained from Replica 14 Bus Rapid Transit Practitioner’s Guide. Transportation Research Board of the National Academies. 2007. 30 City of Riverside
VMT Mitigation Program
o The BRT Practitioner’s Guide notes that the elasticity of ridership based on headway reduction is roughly 40-percent. This means that for every 100-percent increase in frequency or halving of headway, the ridership increases by 40-percent · The average transit trip length for Riverside residents was determined to be 10.5 miles based on Replica data
· The VMT reduction for each transit trip was determined by multiplying additional ridership by average transit trip length
N o t e t h a t t h e V M T r e d u c t i o n e s t i m a t e s s u m m a r i z e d b e l o w m a y b e m o d i f i e d p r i o r t o t h e p r o g r a m ’ s implementation based on additional ridership data obtained from RTA.

T a b l e 6 below summarizes the change in VMT for the transit mitigation measures evaluated for the program. Note that additional transit routes were under consideration for headway reductions, but the existing ridership was so low that this was determined to be infeasible. Specifically, Route 56 that serves UCR and the surrounding area was initially thought to be the perfect candidate for adding an additional bus during peak commute times to increase ridership and reduce vehicle travel. However, after discussions with UCR and RTA, the ridership was deemed too low to show a demand for an additional bus without further route expansion. However, further route expansion would require an additional bus to maintain the existing headway, further increasing the cost of the mitigation measure.

As shown in Table 6 below, Route 15 emerged as the most cost-effective transit mitigation measure with a cost of $1,396 per daily VMT reduced, based on an estimated 3,553 VMT daily reduction. In comparison, Route 10 was found to be the most expensive at $2,582 per daily VMT reduced. The remaining mitigation measures span the range between Route 15 and Route 10 showing a potential for inclusion in the city’s future program.

Table 6 – Summary of Transit Mitigation Measure Evaluation Project ID Route Route Name Cost VMT
Reduced Cost/VMT
41 10 Riverside/Watkins-Galleria $5,900,000 2,285 $2,582 42 22 Riverside - Perris $5,900,000 2,797 $2,109
43 13 Hunter Park Metro-Galleria $5,900,000 2,990 $1,973 44 14 Galleria-Loma Linda VA $5,900,000 3,142 $1,878
45 12 Corona Hills Plaza/Riverside/La
Cadena-Merced $5,900,000 3,553 $1,660
46 15 Riverside/Downtown-Merced $5,900,000 4,227 $1,396 31 City of Riverside
VMT Mitigation Program
Transportation Demand Management (TDM) Mitigation Measures When defining TDM mitigation measures for the City’s VMT mitigation program, mitigation measures that f o c u s e d o n r e d u c i n g c a r t r i p s i n t h e c i t y e i t h e r b y i n c r e a s i n g o c c u p a n c y ( c a r p o o l s a n d v a n p o o l s ) o r incentivizing individual trip reduction (telework or commuter programs) were included. Other types of mitigation measures that may commonly be referred to as TDM mitigation measures for VMT mitigation prior to the advent of VMT Mitigation Programs were not defined as TDM mitigation measures for the purposes of the City’s program as they could be difficult to address or quantify.

For the City’s program, two types of trip reduction mitigation measures were evaluated under the TDM umbrella. Theses mitigation measures demonstrate that increasing the work-from-home (WFH) rate, either daily or once a week, is a cost-effective strategy for reducing VMT, with daily WFH providing the highest cost efficiency. Note that implementing a full telecommute program where workers work from home every day is difficult to implement so while this option is presented, only the work-from-home one day a week, a much more common practice, was considered for inclusion in the City’s program.

Telecommute: Work-From-Home (WFH) Every Day
The analysis of telecommuting as a strategy for reducing Vehicle Miles Traveled (VMT) involves modeling the impact of increased work-from-home rates. Using the Replica big data platform, it was determined that the average commute distance for workers who drive to work and live in the City of Riverside is 16.0 miles. In addition, Census data shows that 63.9-percent of Riverside residents are in the labor force, but t h a t t h e t o t a l n u m b e r o f p e o p l e e m p l o y e d w i t h i n t h e C i t y ( c a n l i v e i n R i v e r s i d e o r e l s e w h e r e ) i s approximately 147,000 as of 2021. Replica data shows that 10.0-percent of the City's workforce, or 14,700 employees, already work from home in some capacity. By increasing the WFH rate by an additional 0.5- percent, equivalent to 735 workers, the daily Citywide VMT can be reduced by 20,801 VMT. The cost of implementing this WFH increase by developing and operating a program to encourage Riverside employers to allow employees to WFH is estimated at $230,000 annually, amounting to $4,600,000 over a 20-year period. This results in a cost efficiency of $221 per VMT reduced.

Telecommute: Work-From-Home (WFH) Once a Week
Similarly, promoting WFH once a week rather than full time also shows potential for VMT reduction, as shown in Table 7. Maintaining the average commute distance of 16.0 miles and the current WFH rate of 10-percent, an additional 0.5-percent WFH once a week for 735 workers could result in a reduction of 4,160 VMT per day. The cost remains at $230,000 per year, totaling $4,600,000 over 20 years, leading to a higher cost per VMT reduction of $1,106.

Table 7 – Summary of TDM Mitigation Measure Evaluation
Project ID Description Cost (20-years) VMT
Reduced Cost/VMT
47 WFH Program (Every Day) $4,600,000 20,801 $221
48 WFH Program (One Day) $4,600,000 4,160 $1,106
32 City of Riverside
VMT Mitigation Program
Recommended VMT Mitigation Measures
The VMT mitigation measures recommended to be included in the City’s VMT Mitigation Program are provided in T a b l e 8 below, known as Option A. As the transit and pedestrian mitigation measures evaluated resulted in high costs per VMT mitigated, the measures summarized in Table 8 are all bicycle mitigation measures. These mitigation measures were chosen based on the criteria established for evaluating potential mitigation measures and their relatively low cost per VMT reduced. Note that the costs included inTable 8 for improvements not submitted for SS4A grants were provided as planning level costs and prior to implementing the City’s VMT Mitigation Program, their costs should be updated with detailed engineering costs. This may result in a change in the overall cost per VMT reduced but is necessary to ensure that adequate funding is provided to enable their construction and implementation.

Table 8 – Recommended VMT Mitigation Measures (Option A) Project ID Roadway Ward Description Cost VMT
Reduced Cost/VMT
14 Columbia
Avenue 1
Stripe bike lane between
American Dr and Salmon
River Rd
$41,719 90 $462
15 Cypress Avenue 6,7 Stripe bike lane between La
Sierra Ave and Crest Ave $38,800 145 $267
16 Orange Street 1
Construct separated
bikeway between 14th St
and 3rd St
$176,239 733 $240
17 Hole Avenue 6
Stripe buffered bike lane
between Collett Ave and
Magnolia Ave
$ 63,360 322 $197
18 Tyler Street 6,7
Stripe bike lane between
Diana Ave and Arlington
Ave
$110,000 571 $193
19 University
Avenue 2
Construct a buffered bike
lane between Iowa Ave and
Campus Dr
$133,358 750 $178
20 Jackson Street 5
Construct bike path
between Diana Ave and
Magnolia Ave
$54,600 310 $176
21 Adams Street 5
Strip buffered bike lane
between Diana Ave and
Arlington Ave
$83,200 738 $113
22 Brockton
Avenue 3 Stripe bike lane between
Magnolia Ave and Beatty Dr $62,605 593 $106
23 California
Avenue 5
Stripe buffered bike lane
between Van Buren Blvd
and Adams St
$76,800 801 $96
33 City of Riverside
VMT Mitigation Program
Project ID Roadway Ward Description Cost VMT
Reduced Cost/VMT
24 Van Buren
Boulevard 5,6
Stripe buffered bike lane
between SR 91 and
Arlington Ave
$161,600 1,904 $85
25 Monroe Street 5
Stripe buffered bike lane
between Diana Ave and
Arlington Ave
$90,400 1,308 $69
26 Gramercy Place 6
Strip bike boulevard
between Crest Ave and
Rutland Ave
$4,400 129 $34
27 Colorado
Avenue 5
Stripe bike boulevard
between Van Buren Blvd
and Adams St
$25,944 1,606 $16
28 Rutland Avenue 6
Stripe bike boulevard
between Wells Ave and
Arlington Ave
$15,072 1,058 $14
29 Wells Avenue 6
Stripe bicycle route
between Tyler St and Crest
Ave
$5,960 614 $10
Total $1,144,057 11,672 $98
While Option A is the most cost-effective option and is the recommended mix of mitigation measures for the City’s program, two other options were developed with higher costs per VMT reduced that include mit igat ion measures t hat are not solely b ic yc le m eas ures. O pt ion B, shown inTa ble 9 below, includes transit mitigation measures centered around reducing headways along existing routes. The headways would be reduced by purchasing an additional bus for each route and hiring an additional driver for that bus to provide increased service during the commute periods. Note that the cost per VMT reduced is about twelve times higher than the amount shown in Table 8 and the VMT available for the program is almost three times the amount provided in Option A.

Table 9 – Recommended VMT Mitigation Measures (Option B) Project
ID Roadway/Route Ward From/To or Route Name Cost VMT
Reduced Cost/VMT
14 Columbia Avenue 1
Stripe bike lane between
American Dr and Salmon
River Rd
$41,719 90 $462
15 Cypress Avenue 6,7 Stripe bike lane between La
Sierra Ave and Crest Ave $38,800 145 $267
16 Orange Street 1 Construct separated bikeway
between 14th St and 3rd St $176,239 733 $240
34 City of Riverside
VMT Mitigation Program
Project
ID Roadway/Route Ward From/To or Route Name Cost VMT
Reduced Cost/VMT
17 Hole Avenue 6
Stripe buffered bike lane
between Collett Ave and
Magnolia Ave
$ 63,360 322 $197
18 Tyler Street 6,7 Stripe bike lane between
Diana Ave and Arlington Ave $110,000 571 $193
19 University Avenue 2
Construct a buffered bike
lane between Iowa Ave and
Campus Dr
$133,358 750 $178
20 Jackson Street 5 Construct bike path between
Diana Ave and Magnolia Ave $54,600 310 $176
21 Adams Street 5
Strip buffered bike lane
between Diana Ave and
Arlington Ave
$83,200 738 $113
22 Brockton Avenue 3 Stripe bike lane between
Magnolia Ave and Beatty Dr $62,605 593 $106
23 California Avenue 5
Stripe buffered bike lane
between Van Buren Blvd and
Adams St
$76,800 801 $96
24 Van Buren
Boulevard 5,6
Stripe buffered bike lane
between SR 91 and Arlington
Ave
$161,600 1,904 $85
25 Monroe Street 5
Stripe buffered bike lane
between Diana Ave and
Arlington Ave
$90,400 1,308 $69
26 Gramercy Place 6 Strip bike boulevard between
Crest Ave and Rutland Ave $4,400 129 $34
27 Colorado Avenue 5
Stripe bike boulevard
between Van Buren Blvd and
Adams St
$25,944 1,606 $16
28 Rutland Avenue 6
Stripe bike boulevard
between Wells Ave and
Arlington Ave
$15,072 1,058 $14
29 Wells Avenue 6 Stripe bicycle route between
Tyler St and Crest Ave $5,960 614 $10
32 10 N/A Riverside/Watkins-Galleria $5,900,000 2,285 $2,582 33 22 N/A Riverside - Perris $5,900,000 2,797 $2,109
34 13 N/A Hunter Park Metro-Galleria $5,900,000 2,990 $1,973 35 City of Riverside
VMT Mitigation Program
Project
ID Roadway/Route Ward From/To or Route Name Cost VMT
Reduced Cost/VMT
35 14 N/A Galleria-Loma Linda VA $5,900,000 3,142 $1,878 36 12 N/A
Corona Hills
Plaza/Riverside/La Cadena-
Merced
$5,900,000 3,553 $1,660
37 15 N/A Riverside/Downtown-Merced $5,900,000 4,227 $1,396 Total $36,544,057 30,666 $1,192
Option C, shown in Table 10 below, includes both transit and pedestrian mitigation measures that would provide a variety of mitigation measures to improve non-motorized travel throughout the City. Option C includes all previous mitigation measures shown in Option B but includes three pedestrian improvements as well. Option C is the most expensive of all of the options and the cost per VMT reduced is thirteen more than the amount shown in Table 8 and about $96 more than the amount shown in Table 9 for Option B while only providing 54 additional VMT for the program.

Table 10 – Recommended VMT Mitigation Measures (Option C) Project ID Roadway/
Route Ward From/To or Route Name Cost VMT
Reduced Cost/VMT
14 Columbia
Avenue 1 Stripe bike lane between American Dr and
Salmon River Rd $41,719 90 $462
15 Cypress Avenue 6,7 Stripe bike lane between La Sierra Ave and Crest Ave $38,800 145 $267
16 Orange Street 1 Construct separated bikeway between 14th St and 3rd St $176,239 733 $240
17 Hole Avenue 6 Stripe buffered bike lane between Collett Ave and Magnolia Ave $ 63,360 322 $197
18 Tyler Street 6,7 Stripe bike lane between Diana Ave and Arlington Ave $110,000 571 $193
19 University
Avenue 2 Construct a buffered bike lane between
Iowa Ave and Campus Dr $133,358 750 $178
20 Jackson Street 5 Construct bike path between Diana Ave and Magnolia Ave $54,600 310 $176
21 Adams Street 5 Strip buffered bike lane between Diana Ave and Arlington Ave $83,200 738 $113
36 City of Riverside
VMT Mitigation Program
Project ID Roadway/
Route Ward From/To or Route Name Cost VMT
Reduced Cost/VMT
22 Brockton
Avenue 3 Stripe bike lane between Magnolia Ave and
Beatty Dr $62,605 593 $106
23 California
Avenue 5 Stripe buffered bike lane between Van
Buren Blvd and Adams St $76,800 801 $96
24 Van Buren
Boulevard 5,6 Stripe buffered bike lane between SR 91
and Arlington Ave $161,600 1,904 $85
25 Monroe Street 5 Stripe buffered bike lane between Diana Ave and Arlington Ave $90,400 1,308 $69
26 Gramercy Place 6 Strip bike boulevard between Crest Ave and Rutland Ave $4,400 129 $34
27 Colorado
Avenue 5 Stripe bike boulevard between Van Buren
Blvd and Adams St $25,944 1,606 $16
28 Rutland Avenue 6 Stripe bike boulevard between Wells Ave and Arlington Ave $15,072 1,058 $14
29 Wells Avenue 6 Stripe bicycle route between Tyler St and Crest Ave $5,960 614 $10
32 10 N/A Riverside/Watkins-Galleria $5,900,000 2,285 $2,582 33 22 N/A Riverside - Perris $5,900,000 2,797 $2,109
34 13 N/A Hunter Park Metro-Galleria $5,900,000 2,990 $1,973 35 14 N/A Galleria-Loma Linda VA $5,900,000 3,142 $1,878 36 12 N/A Corona Hills Plaza/Riverside/La Cadena-
Merced $5,900,000 3,553 $1,660
37 15 N/A Riverside/Downtown-Merced $5,900,000 4,227 $1,396 25 Orange Street 1 Complete street with 5.5-foot sidewalks between SR-60 and Center Street $1,000,000 24 $41,667
22 Main St 1 Complete street with 5-8-foot sidewalks
between Columbia Ave and Santa Ana River $1,000,000 30 $33,333 Total $39,544,057 30,720 $1,287
37 City of Riverside
VMT Mitigation Program
CEQA/Nexus Considerations
Lead agencies are pursuing a range of California Environmental Quality Act (CEQA) strategies to implement VMT mitigation programs based on their selected program’s requirements, other existing CEQA programmatic documentation, the underlying mitigation measures, and preference. The simplest approach is for a lead agency to determine that that the VMT bank is not a “project” under CEQA and is therefore exempt pursuant to CEQA Guidelines Section 15378. This approach centers around the fact that a VMT banking framework, the framework being recommended by this study, does not have a specific commitment to implement any particular mitigation measure. CEQA Guidelines Section 15378 defines a project as an action that has the potential for resulting in either a direct physical change in the environment or a reasonably foreseeable indirect physical change in the environment. Section 15378(b)(4) further clarifies that a project does not include the creation of government funding mechanisms or other government fiscal activities that do not involve any commitment to a specific project which may result in a potentially significant physical impact on the environment.

Unless cleared through prior CEQA documentation, specific mitigation measures would be subject to environmental review. Individual mitigation measures may or may not be found to be individually exempt from CEQA based on their unique characteristics. Likewise, the projects that would potentially participate in a VMT Bank would still have to complete any required environmental review.

As a part of this study, it was determined that preparing a Categorical Exemption (CE) to environmentally clear the City’s VMT mitigation program was the most appropriate path to environmental clearance under CEQA and is provided in Appendix E. As noted in the CE, Section 15262 of CEQA (Feasibility and Planning Studies) states that “a project involving only feasibility or planning studies for possible future actions which the agency, board, or commission has not approved, adopted, or funded does not require the preparation of an EIR or Negative Declaration but does require consideration of environmental factors.

Therefore, the VMT mitigation program would be statutorily exempt from CEQA under a Section 15262 Feasibility and Planning Studies.

Beyond the VMT program itself, there are several important considerations which pertain to the concept of feasible mitigation and nexus which are both required to be addressed by CEQA compliant mitigation.

Feasible Mitigation Considerations
Under CEQA, mitigation refers to measures that can be implemented to reduce or eliminate the significant environmental impacts of a project. Key aspects of mitigation under CEQA to be considered during the program’s implementation include:

1. Avoid the impact altogether by not taking a certain action or parts of an action.

2. Minimize impacts by limiting the degree or magnitude of the action and its implementation.

3. Rectify the impact by repairing, rehabilitating, or restoring the impacted environment.

4. Reduce or eliminate the impact over time by preservation and maintenance operations during the life of the action.

5. Compensate for the impact by replacing or providing substitute resources or environments.
38 City of Riverside
VMT Mitigation Program
CEQA Guidelines Section 21061.1, further clarifies that feasible mitigation measures must be capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social, and technological factors. For a VMT bank, ‘feasible mitigation’ requires particular attention due to the economic viability and timeliness of implementation of the measures within the bank. Depending on the amount of VMT mitigation needed, the cost for development projects using the VMT bank may become financially prohibitive. Additionally, full funding for a mitigation measure may require the participation of multiple projects, which may result in unforeseen delays in implementation given that the timing and need for mitigation payments to a VMT bank are not necessarily under the control of the VMT bank. The City’s approach to address considerations of timeliness are discussed under “Mitigation Timing Considerations” while an approach to economic feasibility will be considered as part of the ongoing General Plan update.

A programmatic EIR allows for more general analysis for the overarching plan which projects can then tier off of assuming that the project is consistent with the plan analyzed under the programmatic EIR, that it is consistent with the zoning, and that it does not trigger the need for a supplemental EIR. Using this approach, the programmatic EIR would establish a VMT bank as a required mitigation measure and address both economic feasibility and timeliness of implementation.

There are examples of agencies that have used EIRs to establish that development or transportation projects consistent with their General Plan do not require additional VMT analysis as their VMT impact was already considered as part of the EIR. In addition, these EIRs have stated that under some circumstances, feasible mitigation does not exist to fully mitigate impacts as part of the agency’s effort to streamline SB 743 analysis for project applicants. It is possible that a VMT bank could be integrated into such an approach and address concerns regarding feasible mitigation as described below. The City is evaluating this approach as part of their ongoing General Plan update.

Economic Feasibility
In practice, the existence of a VMT bank establishes a feasible mitigation option that must be considered for any project within a participating agency’s jurisdiction. Unless the project applicant is able to fully mitigate the project on-site or redefine the project such that there is no need for mitigation, the applicant will be compelled to participate in the VMT bank as it is a feasible mitigation option. However, in the case of projects with higher VMT impacts, payment into the bank to fully mitigate the impact may become financially infeasible for the applicant. The determination of when it becomes infeasible is the point at which the next incremental cost of mitigating an applicant’s project through the VMT mitigation program becomes “unaffordable". It does not alleviate the requirement to pay into the bank, rather it is a determination of the extent to which the project can afford to pay into the bank. The existence of a VMT mitigation program without a pre-existing basis for determination of financial feasibility could result in the City of Riverside being asked by project applicants to decide on a case-by-case basis as to whether their claim of unaffordability is appropriate. Any applicant’s project that is not fully mitigated through participation in the VMT bank or other VMT mitigation measures would be required to pursue a statement of overriding considerations.

As discussed in the prior section, the City is evaluating an approach to utilize the programmatic EIR for the General Plan update to allow for tiering of individual projects. Under this approach, an objective standard for determining the limits of economic feasibility could be developed to reduce the necessity for the City 39 City of Riverside
VMT Mitigation Program
to evaluate each project’s specific financial circumstance if the project applicant were to claim that the mitigation cost was “unaffordable”.

Mitigation Timing Considerations
Unless carefully managed, the timing of VMT mitigation could be a potential issue with CEQA compliance.

Understanding this, the City has developed the following approach to assure that mitigation is completed in a reasonable time frame.

T h e C i t y w i l l o f f s e t t h e c o s t o f m i t i g a t i o n a s n e c e s s a r y t o e n s u r e i t s t i m e l y c o m p l e t i o n . T h i s w i l l b e accomplished either using general funds, bonds, grants, or other funding sources. Note that because the totality of funding for mitigation will not be provided by the City, the requirement of additionality discussed elsewhere will still apply. As part of this program, the City will assure that a commensurate number of VMT credits purchased will be under development with a planned construction date no greater than 5 years after the certificate of occupancy is issued or 5 years after receiving funds.

As mentioned, the City is evaluating alternative approaches to SB 743 as part of its General Plan update which may alter this approach in the future. A programmatic EIR for the General Plan could allow individual projects to tier and mitigate cumulative impacts by contributing to the bank or through the use of other predefined trip reduction measures.

Nexus Documentation
Any land use-based fee programs must "substantially advance legitimate state interests." This involves creating a nexus between the mitigation fee and the government interest. Furthermore, these fees should be proportional to the adverse impacts of the mitigation measures, meaning that mitigation measures should be appropriately sized to offset the actual impact. Under a VMT bank, where VMT reductions are measured in terms of "vehicle miles" or similar units, developers can purchase mitigation that matches the impact of their development project through a fee program. As such, when appropriately implemented, a VMT bank should meet legal nexus requirements.

Proposed VMT Bank
The proposed VMT bank framework differs from traditional fee programs in several ways:

1. Selection of Mitigation Measures: The mitigation measures within the proposed VMT bank would be selected based on the need to mitigate VMT from anticipated development. Unlike traditional fee programs, the application of the fee is directly tied to the individual applicant project and is not based on a future need but the need for VMT mitigation for that applicant project.

2. Calculation and Purchase of Credits: When an applicant project is proposed, the VMT reduction required for the proposal would be calculated, and the applicant would purchase credits equal to the amount of VMT needed for their project.

3. Timely Implementation : Once those VMT credits are purchased, a VMT-reducing mitigation measure would come online within a reasonable timeframe to mitigate the development proposal.
40 City of Riverside
VMT Mitigation Program
Existing Case Law
Relevant court decisions regarding VMT mitigation programs were reviewed to identify examples that are cited most often when adopting and implementing mitigation programs through CEQA. Three cases were identified as being relevant to the development of the City’s VMT mitigation program and are outlined in detail in Appendix A.

Additional Considerations
Agencies need to be diligent in managing VMT mitigation durations as the nexus between improvements and the successful use of fees can vary. Bank arrangements that receive pooled funds from multiple projects should account for the delay between payment and the deployment of funds. This is crucial as it measures the cost of VMT mitigation and negotiates with developers. Agencies must ensure that the timing of the implementation of mitigation measures aligns closely with the development impact to maintain the essential nexus and proportionality as noted above. 41 City of Riverside
VMT Mitigation Program
Case Studies
A case study evaluation was conducted using two projects within the City of Riverside that have already completed their environmental analysis. The two projects are the Wood-Lurin Planned Residential Development15 and the Kaiser Permanente Regional Hospital 16. These projects both resulted in a VMT impact that required mitigation with the Wood-Lurin project requiring 3,013 VMT to fully mitigate its impact and the Kaiser Hospital requiring 9,316 VMT to mitigate its impact. The following summarizes the findings from a situation in which the projects would participate in the City’s VMT bank to mitigate their impacts. Note that these costs represent a worst-case scenario, and the mitigation measures may have some level of cost offset by either City of Riverside funds or outside grants. · Option A would result in a total mitigation cost of approximately $295,280 for the Wood-Lurin project and approximately $912,970 for the Kaiser Hospital project if the VMT Mitigation Program w e r e u s e d t o f u l l y m i t i g a t e e a c h p r o j e c t ’ s i m p a c t . A s t h e W o o d - L u r i n p r o j e c t c o n s i s t s o f 9 6 residential units, the mitigation cost would equate to just under $3,080 per unit. · Option B would result in a total mitigation cost of approximately $3,591,500 for the Wood-Lurin project and approximately $11,104,700 for the Kaiser Hospital project if the VMT Mitigation Program were used to fully mitigate each project’s impact. As the Wood-Lurin project consists of 96 residential units, the mitigation cost would equate to $37,410 per unit. · Option C would result in a total mitigation cost of approximately $3,877,730 for the Wood-Lurin project and approximately $11,989,700 for the Kaiser Hospital project if the VMT Mitigation Program were used to fully mitigate each project’s impact. As the Wood-Lurin project consists of 96 residential units, the mitigation cost would equate to more than $40,390 per unit.

From this analysis, the following observation/findings resulted:
· A mitigation bank may not make all projects financially feasible for mitigation. This challenge could be addressed by reducing the unit cost of VMT mitigation, either by selecting mitigation measures that provide effective VMT reduction at a lower cost, or by using the VMT bank to cover funding gaps, where other funding sources reduce overall costs. This would ensure that projects participating in the VMT bank still have access to complete mitigation solutions. However, it is important that all mitigation measures continue to meet additionality requirements, as outlined elsewhere in this document.

SB 743 was not designed to support a business-as-usual approach to development and transportation p r o j e c t s . I t i s u n d e r s t a n d a b l e t h a t t h e p r o g r a m m a y n o t b e a b l e t o f u l l y m i t i g a t e t h e i m p a c t s o f a l l projects—especially those that conflict with the goals of SB 743. Given the high bar established for VMT thresholds, this outcome is not unexpected. However, CEQA requires projects to still engage in feasible mitigat ion efforts to the greatest extent possible, even if full mitigation is not achievable. Therefore, a 15 Vehicle Miles Traveled (VMT) Analysis for the Wood and Lurin Residential Project. Environment Planning Development Solutions Inc., prepared for the City of Riverside. January 27, 2023. 16 Vehicle Miles Traveled Analysis for the Kaiser Permanente Riverside Medical Center Expansion.LSA Associates, Inc. prepared for the City of Riverside. October 2021.
42 City of Riverside
VMT Mitigation Program
scenario where a project participates in a VMT bank to the extent financially feasible and then seeks a statement of overriding considerations aligns with CEQA’s requirements.

Determining the limits of financial feasibility for projects poses a significant challenge for the a d m i n i s t r a t i o n o f a V M T b a n k . I n s u c h c a s e s , t h e l e a d a g e n c y m a y n e e d t o a s s e s s w h e n a p r o j e c t ' s participation in the bank has reached its financial feasibility limit. One possible approach is to establish a minimum participation level that reduces the project’s impact by at least 15-percent (or another value based on further research) from its initial estimate. Implementing this approach would require further investigation and likely require an Environmental Impact Report (EIR) to address any potentially significant impacts associated with it.
43 City of Riverside
VMT Mitigation Program
Implementation
It is recommended that the City’s VMT mitigation program initially be structured as a voluntary pilot program rather than fully implemented at the onset. A voluntary pilot program will allow the City an o p p o r t u n i t y t o e v a l u a t e t h e p r o g r a m a n d m a k e a d e t e r m i n a t i o n a s t o w h e t h e r i t m e e t s t h e C i t y ’ s objectives and/or whether additional program modifications may be appropriate. A voluntary pilot program can also be conducted with a less formal structure that can provide for needed flexibility during its initial evaluation. Note that the voluntary pilot program will have only a limited availability of VMT credits, assuming the selection of the measures contained within Program Option A, and as such additional VMT mitigation measures will need to be added prior to a full implementation of the program.

Should a full mitigation program be implemented, it would no longer be voluntary for project applicants as it would create a feasible mitigation option. Therefore, project applicants would be required to participate to the extent financially feasible if they are not able to mitigate their VMT impact using other methods. As discussed in the “Feasible Mitigation Considerations” section, a programmatic approach to addressing financial feasibility is being considered as part of the City’s ongoing General Plan update.

The VMT mitigation measures, previously identified as Option A, are recommended to be included in the pilot program and are summarized in Table 11 below. These mitigation measures were chosen based on the criteria established for evaluating potential mitigation measures as described previously. As Option A provides the lowest cost per VMT reduced, it was determined to be the best option to populate the measures included in the voluntary pilot program. In addition to the costs of the improvements, administration costs were included to provide funding for City staff to administer the program through the period that the pilot program is running. The administration costs were set at 2-percent of the total cost of improvements, consistent with other programs currently in operation throughout the state. This results in an addit ional cost per VMT reduced of $2 resulting in an overall pilot program cost per VMT reduced of $100.

Table 11 – Pilot Program VMT Mitigation Measures
Project ID Roadway Ward Description Cost VMT
Reduced Cost/VMT
14 Columbia
Avenue 1 Stripe bike lane between American
Dr and Salmon River Rd $41,719 90 $462
15 Cypress Avenue 6,7 Stripe bike lane between La Sierra Ave and Crest Ave $38,800 145 $267
16 Orange Street 1 Construct separated bikeway
between 14th St and 3rd St $176,239 733 $240
17 Hole Avenue 6 Stripe buffered bike lane between
Collett Ave and Magnolia Ave $ 63,360 322 $197
18 Tyler Street 6,7 Stripe bike lane between Diana Ave
and Arlington Ave $110,000 571 $193
19 University
Avenue 2 Construct a buffered bike lane
between Iowa Ave and Campus Dr $133,358 750 $178
44 City of Riverside
VMT Mitigation Program
Project ID Roadway Ward Description Cost VMT
Reduced Cost/VMT
20 Jackson Street 5 Construct bike path between Diana
Ave and Magnolia Ave $54,600 310 $176
21 Adams Street 5 Strip buffered bike lane between
Diana Ave and Arlington Ave $83,200 738 $113
22 Brockton
Avenue 3 Stripe bike lane between Magnolia
Ave and Beatty Dr $62,605 593 $106
23 California
Avenue 5 Stripe buffered bike lane between
Van Buren Blvd and Adams St $76,800 801 $96
24 Van Buren
Boulevard 5,6 Stripe buffered bike lane between
SR 91 and Arlington Ave $161,600 1,904 $85
25 Monroe Street 5 Stripe buffered bike lane between
Diana Ave and Arlington Ave $90,400 1,308 $69
26 Gramercy Place 6 Strip bike boulevard between Crest
Ave and Rutland Ave $4,400 129 $34
27 Colorado
Avenue 5 Stripe bike boulevard between Van
Buren Blvd and Adams St $25,944 1,606 $16
28 Rutland Avenue 6 Stripe bike boulevard between
Wells Ave and Arlington Ave $15,072 1,058 $14
29 Wells Avenue 6 Stripe bicycle route between Tyler
St and Crest Ave $5,960 614 $10
Subtotal $1,144,057 11,672 $98
Administrative Costs (2% Subtotal) $22,881
Total $1,166,938 11,672 $100
45 City of Riverside
VMT Mitigation Program
Study Findings and Recommendations
Additional findings and recommendations that have resulted from the study include:
· Project Uncertainty Without a VMT Mitigation Solution : Without a clearly defined VMT mitigation program, many projects will face significant uncertainty, potentially stalling progress, even if they align with other plans and programs.
· VMT Mitigation Program as a Solution: A VMT mitigation program offers a new, viable option for addressing VMT impacts that cannot be mitigated through other methods. A VMT bank program is recommended as the most suitable approach for implementation of the City’s VMT mitigation program.
· Selectivity in Mitigation Measures : It is crucial to carefully select VMT-reducing mitigation measures to ensure financial and practical feasibility. These measures should be evaluated for alternative funding sources and compliance with additionality requirements. · Ongoing Process : D e v e l o p i n g m i t i g a t i o n m e a s u r e s f o r t h e C i t y ’ s p r o g r a m w i l l b e a n o n g o i n g process, necessitating accurate methods of VMT analysis in line with best analysis practices to ensure robust outcomes. This study’s established framework should serve as the basis for future analysis.
· Voluntary Pilot Program: It is recommended that the City’s VMT mitigation program initially be structured as a voluntary pilot program rather than fully implemented at the onset. A voluntary p i l o t p r o g r a m w i l l a l l o w t h e C i t y a n o p p o r t u n i t y t o e v a l u a t e t h e p r o g r a m a n d m a k e a determination as to whether it meets the City’s objectives and/or whether additional program modifications may be appropriate. A voluntary pilot program can also be conducted with a less formal structure that can provide for needed flexibility during its initial evaluation. · Support and Participation from Everyone : The program’s success hinges on support from decision-makers, agencies, the community, and participants in the City’s VMT mitigation program. · Periodic Price Changes: If the City’s VMT mitigation program is ultimately implemented the price per VMT reduced may change periodically as the composition of the program and additional funding measures are identified. The prices are current as of publication of this document but should be considered the current price of the program and not the price per VMT reduced in perpetuity.
· Set VMT Threshold at Regional Average: it is recommended that the City of Riverside set its VMT significance thresholds for VMT per capita and VMT per employee at the regional average rather than 15-percent below the regional average. Implementing this change would bring the City’s VMT analysis methodology in line with the methodology of neighboring jurisdictions such as the City of San Bernardino, Riverside County, and the City of Jurupa Valley.

City of Riverside
VMT Mitigation Program
Appendix A: Literature Review and Existing Case Law
1 City of Riverside
VMT Mitigation Program
Literature Review
The literature review completed as a part of this study provides a comprehensive overview of Vehicle Miles Traveled (VMT) mitigation programs implemented across jurisdictions in California under SB 743.

The review examines actual programs, relevant initiatives, and current practices, showcasing the diverse approaches employed to address VMT reduction and promote sustainable transportation choices.

The programs reviewed employ a variety of strategies, including active transportation infrastructure investment, transportation analysis policies, VMT monitoring apps, telework incentives, VMT mitigation programs, and fees based on VMT. These strategies aim to reduce VMT impacts, encourage sustainable travel modes, and generate funds for transportation improvements.

By highlighting these programs, the review illuminated the practical implementation of VMT reduction strategies, their community impacts, and the challenges encountered during their execution. Valuable lessons were drawn from the experiences of California jurisdictions, providing a deeper understanding of the evolving landscape of VMT mitigation.

Furthermore, the review explored complementary initiatives and current practices across California, offering a well-rounded perspective on the strategies employed by jurisdictions to reduce VMT and promote sustainable transportation choices.

The review addressed diverse case studies, existing programs in the LA/Riverside region, exemplary initiatives, and noteworthy best practices, showcasing the multifaceted challenges faced and the creative solutions devised by California jurisdictions. These examples underscore their ongoing commitment to sustainable transportation and the pursuit of a greener future. Programs reviewed included those implemented by the City of San Diego, the City of San Jose, the Contra Costa Transportation Authority (CCTA), the San Bernardino County Transportation Authority (SBCTA), and the Tahoe Regional Planning Agency (TRPA).

This literature review was intended to serve as a valuable resource for the City of Riverside, presenting a compendium of experiences and lessons learned from the forefront of VMT mitigation. It equips Riverside with the knowledge and insights necessary to navigate the complexities of VMT reduction effectively, contributing to a greener and more sustainable future.

Existing Case Law
The court decisions that were determined to be relevant to the development of the City’s VMT Mitigation Program are summarized in Table 12 below. As shown in Table 12, three cases in particular were found to be relevant, though the most recent case was completed in 1994. As VMT Mitigation Programs are a relatively new type of mitigation program, these cases center more around CEQA mitigation as a whole, rather than VMT mitigation itself.
2 City of Riverside
VMT Mitigation Program
Table 12 – Existing Case Law Relevant to Developing a VMT Mitigation Program Case Decision Summary VMT Bank VMT
Exchange
VMT
Impact Fee
Nollan v. California
Coastal Commission,
483 U.S. 825 (1987)
The Court held that a government could, without
paying compensation, demand an easement as a
condition for granting a development permit the
government was entitled to deny, provided that the
exaction would substantially advance the same
government interest that would furnish a valid
ground for denial of the permit, or in other words
that there is an appropriate “nexus” between the
project’s effect and the mitigation. This is known as
the “nexus” test.

Relevant Relevant Relevant
Dolan v. City of Tigard,
512 U.S.
374 (1994)
The Court further refined the Nollan requirement in
Dolan, holding that an adjudicative exaction
requiring dedication of private property must also
be “‘roughly proportional’ . . . both in nature and
extent to the impact of the proposed development.”
This is known as the “rough proportionality” test.

Relevant Relevant Relevant
Sacramento Old City
Assoc. V City Council of
Sacramento, 229 Cal
App 3d 2011 (1991)
In this case, the court established the conditions
under which identification of mitigation specifics
can be properly deferred beyond the point of CEQA
compliance: If the specifics cannot be identified at
the time of CEQA compliance, then 1) the agency
must commit itself to the mitigation and identify
one or more measures for the significant effect and
must establish clear performance standards; or 2)
alternatively the agency must provide a menu of
feasible mitigation options that can be selected to
meet the stated performance standards.

Relevant Relevant Relevant
City of Riverside
VMT Mitigation Program
Appendix B: State of the Practice
1 City of Riverside
VMT Mitigation Program
State of the Practice
Table 13 below provides a high-level summary of the current state of the practice in California of fee- based VMT reduction/mitigation programs. As shown inTable 13, there are relatively few fee-based VMT reduction/mitigation programs active in the state. Some of the programs included are not specifically focused on meeting CEQA VMT mitigation needs (they instead are focused on general VMT reductions), however they are still important models that show how specific elements programs being considered by the study could function.

Table 13 – Fee-based VMT Mitigation Program State of the Practice Agency VMT Mitigation
Program Format Status
Cost per VMT
Reduced ($/VMT
Reduced)
City of Escondido VMT Exchange Implemented in 2023, with a cost basis varying for each measure Varies by Measure
City of Fresno TBD Ongoing --
City of Hollister VMT Bank Study completed. Pending adoption and implementation. --
City of Lancaster
VMT Mitigation
Fee Optional
Program
Implemented in 2023, with a cost basis
of $150/VMT $150/VMT reduced
City of Palmdale VMT Bank Implemented 2024, with a cost basis of $261/VMT. $261/VMT reduced
City of Salinas VMT Bank Study completed. Pending adoption and implementation. --
City of San Diego
Active
Transportation In-
Lieu Impact Fee
Implemented in 2020, with a cost basis
of $1,400/VMT. $1,400/VMT reduced
City of Tracy VMT Bank Study completed. Pending adoption and implementation. --
City of Watsonville VMT Bank Implemented March 2023, with a cost basis of $1,524/VMT
$1,524/VMT reduced
(maximum)
Coachella Valley Association
of Governments (CVAG) TBD Study funded under REAP 2.0. Not yet started. --
Contra Costa Transportation
Authority (CCTA) TBD Study completed in 2023. Pilot program under development. --
2 City of Riverside
VMT Mitigation Program
Agency VMT Mitigation
Program Format Status
Cost per VMT
Reduced ($/VMT
Reduced)
Fresno COG VMT Bank
Study completed in 2023. An additional
study is being considered to define
remaining program elements required
for implementation.
--
Los Angeles County State
Highway System
VMT Bank for State
Highway System
Program adopted by Metro Board in
2024. Pilot program under
development.
--
San Bernardino County
Transportation Authority
(SBCTA)
VMT Bank
$2,000,000 in grant funds awarded in
2024 to seed identified mitigation
measures. Telework program expected
to result in $161/VMT reduced
$161/VMT reduced
San Luis Obispo Council of
Governments (SLOCOG) TBD Framework development on-going, release expected September 2024 --
Santa Clara Valley
Transportation Authority
(VTA)
TBD Ongoing --
Santa Cruz County and
incorporated Cities VMT Bank Ongoing --
Stanislaus Council of
Governments (StanCOG) TBD Study funded under REAP 2.0. Not yet started. --
Town of Los Gatos Not Determined Study completed. Implementation not planned. --
Transportation Authority of
Marin (TAM) TBD Ongoing --
Various
Non-CEQA VMT
Based Impact Fee
Programs
There are numerous examples of
traditional VMT Impact Fees that define
impacts in terms of VMT in lieu of trips.
--
Western Riverside Council of
Governments (WRCOG) VMT Exchange Program development under consideration. --
City of Riverside
VMT Mitigation Program
Appendix C: Outreach Materials
kimley-horn.com 555 Capitol Mall, Suite 300, Sacramento, California 95814 916 858 5800 Memorandum
To: Philip Nitollama, T.E.

Vital Patel
City of Riverside
From: Chris Gregerson, P.E., T.E., PTOE, PTP
Mike Schmitt, AICP CTP, PTP, RSP1
Re: City of Riverside VMT Mitigation Program
Outreach Plan
Date: May 30, 2023
Introduction
A key component of the development of the City of Riverside’s Vehicle Miles Traveled (VMT) Mitigation Program is input from stakeholders and the general public to help inform the framework and implementation of the Program. This Outreach Plan is developed to summarize the efforts to engage and seek feedback from potential stakeholders and interested community members. The following sections will identify several ways to reach all the demographics of the City of Riverside community, including disadvantaged communities to ensure equity in the benefits provided by the implementation of the VMT Mitigation Program.

Outreach Approach
The outreach effort for this project is designed to encourage the active participation of a broad range of stakeholder groups in the planning process. The Program’s Outreach Plan has the following two high-level outreach goals:
§ Engage the broadest cross section of the City’s residents, businesses, and decision makers in developing the VMT Mitigation Programs including the Program’s framework (e.g., VMT Mitigation Bank, VMT Exchange, or other options) and types of projects included. § Make the Program’s development process accessible, interactive, and engaging.

To develop the VMT Mitigation Program, Kimley-Horn and the City will engage a variety of audiences that may use the program, be involved in future development within the City, are involved in housing issues within the City, or otherwise benefit by construction or implementation of the VMT mitigation projects that will be included in the Program in the future. This includes organizations advocating or representing disadvantaged communities, business and economic development interests that operate in the City, elected and appointed officials, and the general public.

The communications strategy for the project will include the following key elements, which are discussed in the following sections:
§ Stakeholder Advisory Committee (SAC) Meetings
§ Agency Consultations
§ Project Website
§ Public Meeting
City of Riverside VMT Mitigation Program Page 2 of 3
Outreach Plan May 30, 2023
Stakeholder Advisory Committee (SAC) Meetings
The primary outreach approach includes monthly or semi-monthly Stakeholders Advisory Committee (SAC) meetings. The first SAC meeting was held on May 3, 2023, and the second meeting is scheduled to be held on June 7, 2023. The SAC includes a variety of interested parties including neighborhood groups within the City of Riverside, representatives of educational institutions within the City including both K-12 and higher education institutions such as the University of California Riverside, Community Based Organizations (CBOs), Chambers of Commerce within the City, members of the development community, and others.

Generally, the purpose of the SAC is to provide direction and make recommendations to Kimley-Horn and the City in its development of the VMT Mitigation Program. Specifically, the purpose of the SAC meetings is to provide education opportunities regarding the project, solicit feedback regarding the development of the Program Framework and other key project components, and provide project updates throughout the project lifecycle.

Agency Consultations
In addition to the community outreach, Kimley-Horn and the City will hold virtual meetings with key agency stakeholders to solicit VMT reduction projects that could be included in the program, as well as feedback on the overall framework of the VMT Mitigation Program. The following organizations have been identified for agency consultation meetings:
§ Western Riverside Council of Governments (WRCOG)
§ University of California Riverside
§ Riverside Transit Agency
§ Riverside County Transportation Commission (Metrolink) § County of Riverside
§ Up to three cities adjacent to the City of Riverside
Project Website
A project website will be developed that will include a project instructional video, background information for the video, project updates, and participation opportunities includingpublic meetings and any online surveys developed.

The instructional video included on the website will be a presentation with a voiceover that provides a brief background on VMT, the purpose of the project, and VMT Mitigation Program Framework options.

The website will also contain a link to a graphics-heavy document that provides additional information on the topics covered by the instructional video. The purpose of this document is to help inform the reader of all things VMT so they can provide informed feedback at decision points in the project and answer surveys in an informed manner.

The project website will also be structured to provide a timeline of project updates and information on participation opportunities so the reader can easily follow what has already occurred and what is still planned in the future so they can track the project progress throughout the project lifecycle.

Public Meeting
In addition to the SAC meetings, one in person public meeting will be held later in the project lifecycle once the draft VMT Mitigation Program has been developed. This in person meeting will serve to provide an opportunity for City residents to learn about the Program and offer feedback. The public meeting will City of Riverside VMT Mitigation Program Page 3 of 3
Outreach Plan May 30, 2023
be held at the City’s library and for those who are unable to attend, a recording of the public meeting will be posted to the project website.
kimley-horn.com 555 Capitol Mall, Suite 300, Sacramento, California 95814 916 858 5800 Memorandum
To: Philip Nitollama, T.E.

Engage the broadest cross section of the City’s residents, businesses, and decision makers in developing the VMT Mitigation Programs including the Program’s framework (e.g., VMT Mitigation Bank, VMT Exchange, or other options) and types of projects included.

Make the Program’s development process accessible, interactive, and engaging.

The communications strategy for the project will include the following key elements, which are discussed in the following sections:

Stakeholder Advisory Committee (SAC) Meetings
Agency Consultations
Project Website
Public Meeting
City of Riverside VMT Mitigation Program Page 2 of 3
Outreach Plan May 30, 2023
Stakeholder Advisory Committee (SAC) Meetings
The primary outreach approach includes monthly or semi-monthly Stakeholders Advisory Committee (SAC) meetings. The first SAC meeting was held on May 3, 2023, and the second meeting is scheduled to be held on June 7, 2023. The SAC includes a variety of interested parties including neighborhood groups within the City of Riverside, representatives of educational institutions within the City including both K-12 and higher education institutions such as the University of California Riverside, Community Based Organizations (CBOs), Chambers of Commerce within the City, members of the development community, and others.

Western Riverside Council of Governments (WRCOG)
University of California Riverside
Riverside Transit Agency
Riverside County Transportation Commission (Metrolink)
County of Riverside
Up to three cities adjacent to the City of Riverside
Project Website
A project website will be developed that will include a project instructional video, background information for the video, project updates, and participation opportunities including public meetings and any online surveys developed.

Vital Patel
City of Riverside
From: Chris Gregerson, P.E., T.E., AICP
Mike Schmitt, AICP CTP, PTP, RSP1
Re: City of Riverside VMT Mitigation Program
Outreach Event Summary
Date: March 7, 2024
Stakeholder Advisory Committee (SAC) Meeting #1 (May 3, 2023) This was the first meeting held with the Stakeholder Advisory Meeting (SAC) for the City of Riverside’s Vehicle Miles Traveled (VMT) Mitigation Program project. Kimley-Horn worked with the City to develop a list of project stakeholders to invite to the meeting including representatives of the City’s neighborhood groups, representatives of the development community, public entities within the City including the University of California at Riverside (UCR), regional public entities such as Riverside County, the Western Riverside Council of Governments (WRCOG), and the Riverside Transit Agency. In total, approximately 40 SAC members were identified and invited to participate in the meeting. The meeting was attended by 15- 20 of the invited stakeholders with questions asked throughout the presentation regarding VMT and the VMT Mitigation Program
Observations
There was a large range in familiarity with VMT from those who only heard about it once or twice to those who work on policies related to VMT
Many of the attendees were interested in the purpose of a VMT Mitigation Program Key Topics of Conversation
How VMT impacts are determined
Why the City of Riverside needs a VMT Mitigation Program How would a VMT Mitigation Program work
Lessons Learned
With a wide range of VMT familiarity, it is important to provide a base level of understanding to better inform about the program, but that cannot come of not being able to get through the material that is relevant to all stakeholders
kimley-horn.com 555 Capitol Mall, Suite 300, Sacramento, California 95814 916 858 5800 Memorandum
To: Philip Nitollama, T.E.

Observations
VMT Mitigation Programs are very technical in nature and it can be difficult to engage a wide audience on the topic
The summary of the state of the practice drew significant interest as the topic of VMT Mitigation Programs is very new
Key Topics of Conversation
The state of the practice for VMT Mitigation Programs
What is, and is not, covered by the study
Outreach planned to be completed as a part of the study Lessons Learned
Providing specific breaks in the presentation for meeting participants to ask questions allowed the presentation to flow at a reasonable pace
Providing context for the study and the City’s need for the VMT Mitigation Program helped engage the meeting participants
kimley-horn.com 555 Capitol Mall, Suite 300, Sacramento, California 95814 916 858 5800 Memorandum
To: Philip Nitollama, T.E.

Observations
The decrease in stakeholder members attending the meeting has continued since the first SAC meeting
The topic that garnered the most engagement from the attendees was how the program would be administered
Key Topics of Conversation
Framework options for the program
Administration options for the program
Additionality
Project online survey
kimley-horn.com 555 Capitol Mall, Suite 300, Sacramento, California 95814 916 858 5800 Memorandum
To: Philip Nitollama, T.E.

Vital Patel
City of Riverside
From: Chris Gregerson, P.E., T.E., AICP
Mike Schmitt, AICP CTP, PTP, RSP1
Re: City of Riverside VMT Mitigation Program
Outreach Event Summary
Date: March 7, 2024
Stakeholder Advisory Committee (SAC) Meeting #4 (September 28, 2023) This was the fourth meeting held with the Stakeholder Advisory Meeting (SAC) for the City of Riverside’s Vehicle Miles Traveled (VMT) Mitigation Program project. The meeting was attended by 5 of the invited stakeholders with few questions asked throughout the presentation. The presentation began by summarizing the meetings held with the Western Riverside Council of Governments (WRCOG), Riverside County, the Riverside Transit Authority (RTA), and the university of California at Riverside (UCR). The focus of these meetings were to have direct engagement with agencies regarding the program and to solicit VMT reducing project ideas that could be evaluated as a part of the program. The presentation then covered the project evaluations that had been completed to date including 10 bicycle and pedestrian projects, 15 transit projects, and three transportation demand management (TDM) projects. The presentation concluded by summarizing the findings of the project evaluation including what the cost per VMT reduced was determined for each individual project resulted and what still needed to be evaluated.

Observations
There was real interest in how VMT reducing projects were evaluated and how each project compared to each other in terms of cost per each VMT reduced Participants were eager to understand how the overall program would function once VMT reducing projects were chosen for the program and what the cost would be for a typical development project with a VMT impact
Key Topics of Conversation
VMT mitigation timing
How VMT reducing projects (bike/ped, transit, and TDM) are evaluated to determine the amount of VMT reduced
Project cost per VMT reduced
Lessons Learned
While transit projects can reduce the most VMT, they are also the most costly resulting in a cost per VMT reduced that is difficult to compete with active transportation projects (bike/ped) TDM programs, such as a work from home program, are the most efficient but the hardest to implement
kimley-horn.com 555 Capitol Mall, Suite 300, Sacramento, California 95814 916 858 5800 Memorandum
To: Philip Nitollama, T.E.

The presentation began by summarizing the public outreach conducted so far including the online survey released to the public and the public meeting held on December 14, 2023. The presentation continued covering the evaluation of the program frameworks, the recommended framework for the City’s program (VMT Bank), the results of the evaluation of the VMT reducing projects selected for inclusion in the City’s program, the total VMT reduced and cost per VMT calculated for the City’s Program, an overview of implementing the Program and administration considerations, and concluded with some case studies of how past development projects may have interacted with the Program were it implemented when the projects were going through their environmental analyses.

The meeting also summarized the findings and remaining steps with tentative dates for completing the evaluation portion of the Program. In addition, the meeting provided an opportunity for participants to provide input on a logo for the City’s Program.

Attendees

1. Mike Schmitt – Kimley-Horn

2. Chris Gregerson – Kimley-Horn

3. Vital Patel – City of Riverside

4. Kevin Tsang – County of Riverside

5. Guoyuan Wu – University of California, Riverside Center for Environmental Research & Technology

6. Lou Monville – Building Industry Association Riverside Chapter

7. Miguel Lujano – Riverside Community Health Foundation

8. Mike Gainor – Southern California Association of Governments City of Riverside VMT Mitigation Program Page 2 of 2
Outreach Event Summary April 4, 2024
Observations
There is still some hesitation about the City implementing a VMT Mitigation Program if there are few examples of other programs being implemented throughout California Logo #3 was the preferred logo for the Program
Key Topics of Conversation
Whether the community was used to provide feedback for the projects selected for inclusion in the City’s Program
Whether the projects selected for inclusion in the City’s Program were screened to determine whether they were included in other programs
The status of fully implemented VMT mitigation programs throughout California, as well as the status of programs in development in the region including the one being developed by the Western Riverside Council of Governments (WRCOG)
The status of environmental clearance requirements for the City’s Program The remaining schedule for completing the Program
Lessons Learned
Ongoing community engagement will be key for successfully implementing the City’s VMT Mitigation Program
A VMT Banking framework would be the most appropriate initial program Reproducible methods for evaluating VMT mitigation have been established kimley-horn.com 555 Capitol Mall, Suite 300, Sacramento, California 95814 916 858 5800 Memorandum
To: Philip Nitollama, T.E.

The presentation began by restating the purpose of the study and summarizing the public outreach conducted so far including the online survey released to the public and the public meeting held on December 14, 2023. The presentation continued covering recommended program framework for the City’s program (VMT bank), a summary of the VMT reducing measures evaluated for inclusion in the City’s program and those that were ultimately recommended for inclusion, three options for mixtures of VMT reducing measures to include in the program including the total cost, VMT reduced and overall cost per VMT reduced for each option, a comparison table of programs in the state and their respective costs per VMT reduced, two case study examples, a demo of the TREDLite VMT tool, a summary of mitigation timing considerations, and concluded with findings and remaining steps for the City’s program. In addition, the meeting provided an opportunity for participants to ask questions about the City’s Program.

Attendees

1. Mike Schmitt – Kimley-Horn

2. Chris Gregerson – Kimley-Horn

3. Vital Patel – City of Riverside

4. Kevin Tsang – County of Riverside

5. Lou Monville – Building Industry Association Riverside Chapter

6. Miguel Lujano – Riverside Community Health Foundation

7. Warren Whiteaker – Southern California Association of Governments

8. Janice Penner – Riverside Downtown Partnership

9. Irma Henderson - University of California, Riverside City of Riverside VMT Mitigation Program Page 2 of 2
Outreach Event Summary October 17, 2024
Observations
· There is support for the City implementing a VMT Mitigation Program, but cost will be a serious factor in the success of the program
Key Topics of Conversation
· Whether other jurisdictions are using TREDLite to estimate VMT impacts · How other VMT reducing measures can be added to the City’s program · How often the program will be updated with additional measures · How the program will fit into the overall CEQA mitigation needs for future development projects · The remaining schedule for completing the Program
Lessons Learned
· Ongoing community engagement will be key for successfully implementing the City’s VMT Mitigation Program
· Reproducible methods for evaluating VMT mitigation have been established · An avenue should be created for the community to submit VMT reducing measures to be considered for inclusion in the City’s program
kimley-horn.com 555 Capitol Mall, Suite 300, Sacramento, California 95814 916 858 5800 Memorandum
To: Philip Nitollama, T.E.

Vital Patel
City of Riverside
From: Chris Gregerson, P.E., T.E., AICP
Mike Schmitt, AICP CTP, PTP, RSP1
Re: City of Riverside VMT Mitigation Program
Outreach Event Summary
Date: March 7, 2024
Agency Meeting with Riverside County (August 31, 2023)
This was the second meeting held with an agency to discuss the City of Riverside’s VMT Mitigation Program directly. The meeting was held with the project team (Kimley-Horn and the City of Riverside) and two members of Riverside County. The meeting began by noting that Kimley-Horn developed the County’s VMT policy to provide background context for the meeting. The discussion then focused whether Riverside County was planning to develop a VMT Mitigation Program or if not, what their level of involvement would be in other programs in the region. The discussion then focused on VMT reducing projects in the region and how a City of Riverside VMT Mitigation Program would function. The meeting concluded with the City providing the County with a schedule for implementing their VMT Mitigation Program.

Observations
Riverside County is aware of WRCOG developing a VMT Mitigation Program and noted they do not have a VMT Mitigation Program of their own
Key Topics of Conversation
The status of VMT Mitigation Programs in the Western Riverside region Riverside County’s involvement in VMT Mitigation Programs How a VMT Mitigation Program would function
How to ensure that if funding is provided to a VMT Mitigation program, projects included in the program are implemented or constructed
Key Takeaways
Riverside County is interested in participating in a regional VMT Mitigation Program, but is not interested in developing their own
VMT reducing projects included in a VMT Mitigation Program would need to be implemented in a timely fashion
A backstop is needed to sure that VMT reducing projects are constructed if they are included in a VMT Mitigation Program and funds are contributed to the program by projects with VMT impacts kimley-horn.com 555 Capitol Mall, Suite 300, Sacramento, California 95814 916 858 5800 Memorandum
To: Philip Nitollama, T.E.

Vital Patel
City of Riverside
From: Chris Gregerson, P.E., T.E., AICP
Mike Schmitt, AICP CTP, PTP, RSP1
Re: City of Riverside VMT Mitigation Program
Outreach Event Summary
Date: March 7, 2024
Agency Meeting with the Riverside Transit Authority ( 1 , 2023) This was the third meeting held with an agency to discuss the City of Riverside’s VMT Mitigation Program directly. The meeting was held with the project team (Kimley-Horn and the City of Riverside) and Jennifer Nguyen at RTA. The meeting’s focus was on the potential of transit projects to be included in the City’s VMT Mitigation Program. The discussion began with the initial transit project evaluations completed by the project team in which the VMT reductions produced by additional buses being added along routes to reduce headways were determined. The discussion then evolved into other types of transit projects and whether they were feasible or had been tested in the past such as reduced/free transit passes for specific populations and micro transit expansion. The discussion concluded with how funding from the City’s VMT Mitigation Program would go towards any transit projects included in the program in terms of on-going costs over a 20-year lifecycle.

Observations
RTA is interested in participating in Stakeholder meetings, but they have been scheduled during RTA board meetings in the past
RTA is working with WRCOG on their regional VMT Mitigation Program, but nothing has been decided at this time
Ridership is at 80-percent of pre=COVID levels
RTA is able to provide ridership data to aid in the evaluation of VMT reducing projects Key Topics of Conversation
Initial project evaluations and the associated VMT reductions Other potential VMT reducing projects that could be evaluated for inclusion in the City’s VMT Mitigation Program
The effectiveness of reduced for free transit passes
Which routes would be most effective in increasing ridership if headways were reduced Key Takeaways
RTA tracks ridership, passenger miles traveled, and passenger average trip distance RTA is willing to share data on a per route basis & guidance on headway reductions RTA has conducted several fare reduction promotions
o These programs could lead to pure VMT reductions
City of Riverside VMT Mitigation Program Page 2 of 2
Outreach Event Summary March 7, 2024
Route 56 (new route that services the University of California at Riverside and surrounding areas) is still building ridership
o It started in January 2023 with a 1-hour headway
o There is a question of whether extending the route to the industrial area to the north would increase ridership, but this extension would also need to include an additional bus along the route which would require additional funding
kimley-horn.com 555 Capitol Mall, Suite 300, Sacramento, California 95814 916 858 5800 Memorandum
To: Philip Nitollama, T.E.

Vital Patel
City of Riverside
From: Chris Gregerson, P.E., T.E., AICP
Mike Schmitt, AICP CTP, PTP, RSP1
Re: City of Riverside VMT Mitigation Program
Outreach Event Summary
Date: March 7, 2024
Agency Meeting with the University of California at Riverside (September 20, 2023) This was the fourth meeting held with an agency to discuss the City of Riverside’s VMT Mitigation Program directly. The meeting was held with the project team (Kimley-Horn and the City of Riverside) and Irma Henderson at UCR. The meeting’s focus was on UCR’s relationship with the Riverside Transit Authority (RTA) and the types of projects UCR would like to see funded by the City of Riverside’s VMT Mitigation Program. The discussion initially focused on Route 56, a new route that serves UCR and links the campus to Metrolink. The discussion then moved to UCR’s initial relationship with RTA regarding Route 51 the history of that route in terms of ridership and funding. Bicycle and vanpool projects connecting and serving UCR were also discussed before the meeting concluded.

Observations
Route 56 has served a number of challenges UCR has experienced including connecting the campus directly with Metrolink and its partners in the area such as the California Air Resources Board (CARB)
o UCR is attempting to add an additional stop next to CARB’s building RTA gives all boarding data to UCR for Route 51 and Route 56 Route 51 was achieving its farebox revenue pre-COVID
Route 51 and 56 help solve the campus’ ADA needs
There are gaps between cycle tracks connecting campus to the surrounding areas that the City’s VMT Mitigation Program could include as projects to fund Key Topics of Conversation
Route 51 and Route 56
Long-term funding and ridership challenges
Bicycle projects and vanpool programs
Key Takeaways
Route 56 (new route that services the University of California at Riverside and surrounding areas) is still building ridership
o It started in January 2023 with a 1-hour headway
o There is a question of whether extending the route to the industrial area to the north would increase ridership by serving a larger population, but this extension would also need to include an additional bus along the route which would require additional funding kimley-horn.com 555 Capitol Mall, Suite 300, Sacramento, California 95814 916 858 5800 Memorandum
To: Philip Nitollama, T.E.

Vital Patel
City of Riverside
From: Chris Gregerson, P.E., T.E., AICP
Mike Schmitt, AICP CTP, PTP, RSP1
Re: City of Riverside VMT Mitigation Program
Outreach Event Summary
Date: March 7, 2024
Agency Meeting with the Western Riverside Council of Governments (August 30, 2023) This was the first meeting held with an agency to discuss the rogram directly. The meeting was held with the project team (Kimley-Horn and the City of Riverside) and two members of WRCOG. The meeting began by discussing VMT policy in terms of what WRCOG has developed and what WRCOG’s member agencies developed. The discussion then focused on the administration and participation of VMT Mitigation Programs, Caltrans’ involvement in the development of WRCOG’s program (it is not involved), how VMT policy has changed development patterns in western Riverside County and concluded with the timeline for implementation of WRCOG’s VMT Mitigation Program.

Observations
While WRCOG will determine the effectiveness of the VMT reduced by projects being submitted to being included in their program, they don’t think that having a program available means everyone needs to participate
Transportation projects are slowing down or stopping because of VMT mitigation costs Fewer retail and office development projects are being submitted, it is mostly single-family residential, multi-family residential, and industrial projects VMT Mitigation Programs can help with partial mitigation of impacts Key Topics of Conversation
The concept of additionality and how it will impact the administration of VMT Mitigation Programs
How project applicants will interact with a VMT Mitigation Program Types of development projects coming forward compared to before VMT policies were implemented
Key Takeaways
WRCOG is developing a VMT Mitigation Program that will likely use the Exchange framework WRCOG will administer their program and determine the VMT reductions for any VMT reducing projects submitted
WRCOG is targeting the end of 2024 for implementation
WRCOG has no issue with the City of Riverside developing its own VMT Mitigation Program in parallel with their own program
kimley-horn.com 555 Capitol Mall, Suite 300, Sacramento, California 95814 916 858 5800 Memorandum
To: Philip Nitollama, T.E.

Vital Patel
City of Riverside
From: Chris Gregerson, P.E., T.E., AICP
Mike Schmitt, AICP CTP, PTP, RSP1
Re: City of Riverside VMT Mitigation Program
Outreach Event Summary
Date: March 7, 2024
Public Meeting #1 (December 14, 2023)
This was the first meeting held that was open to the public. It was held at the Riverside Main Library from 5:30 to 7:00 PM and included a presentation held by the project team and an open forum with boards provided that showcased the types of VMT reducing projects being considered for the City’s VMT Mitigation Program and their respective location throughout the City. The meeting was attended by eight members of the public who were encouraged to ask questions about the program throughout the presentation. The project team was also available to answer any other questions or discuss topics with the public after the conclusion of the presentation.

Observations
Most of the input received was about perceived increases to costs/taxes and several members were concerned they were going to see an increase in housing costs and annual fees they were required to pay by the City
Many clarifying questions about VMT analysis vs VMT mitigation Some members of the public were concerned about the types of projects that would be funded by the program and whether they would be effective at reducing as much VMT as was estimated The public was not against the implementation of the program, but wanted to make sure only development projects would be required to interact with the City Key Topics of Conversation
The need for a VMT Mitigation program and how it would work once implemented What work had been completed for the study so far in the project life cycle What types of VMT reducing projects were being considered to be funded by the VMT Mitigation Program
Whether the introduction of the VMT Mitigation Program would lead to an increase of housing costs for residents of the City of Riverside
Lessons Learned
The presentation should begin by stating that no increase in fees to the public at large was being proposed as a part of the implementation of the VMT Mitigation Program The public generally has a limited understanding of VMT policy, but is very concerned about any program that could raise housing costs or costs to the public in general kimley-horn.com 555 Capitol Mall, Suite 300, Sacramento, California 95814 916 858 5800 Memorandum
To: Philip Nitollama, T.E.

Vital Patel
City of Riverside
From: Chris Gregerson, P.E., T.E., AICP
Mike Schmitt, AICP CTP, PTP, RSP1
Re: City of Riverside VMT Mitigation Program
Outreach Event Summary
Date: March 8, 2024
Public Online Survey (December 2023)
In advance of the public meeting held on December 14, 2023, an eight-question survey was posted online and advertised by the City to solicit input from the public on the City’s VMT Mitigation Program. The online survey targeted members of the public who could not make the public meeting, but also was intended to provide information about the City’s VMT Mitigation Program in advance of the public meeting for members of the public who planned on attending. Questions covered topics such as the respondent’s familiarity with VMT and fee programs, how fees are charged and spent as part of a VMT Mitigation Program, the types of projects that should be included in a VMT Mitigation Program, and any concerns the respondent may have about a VMT Mitigation Program. The online survey was advertised by the City on all its social media accounts and a link to the survey was included in the flier advertising the public meeting. A hard copy of the survey was also provided to attendees of the public meeting.

Observations
15 responses were received and all were from residents, no business owners responded One person did not respond to two of the questions regarding transportation demand measures and whether a portion of the fees generation should be spent locally There was no clear consensus on the types of VMT reducing projects that should be funded by the VMT Mitigation Program
Key Takeaways
13% of respondents were familiar with VMT state requirements 40% of respondents support a developer fee program
70% of respondents were in favor of fees based on amount of VMT vs size of project Respondents ranked Bike/ped and telecommute projects highest 93% of respondents were in favor of mitigation based on project location 12/14/23, 10:20 AM City of Riverside Vehicle Miles Traveled Mitigation Program Project Survey https://www.surveymonkey.com/r/RiversideVMT 1/5
City of Riverside Vehicle Miles
Traveled Mitigation Program Project
Survey
SB 743, signed into law in 2013, required the
Governor’s Oﬃce of Planning and Research (OPR) to
establish a new metric for identifying and mitigating
transportation impacts for projects that are subject
to the California Environmental Quality Act (CEQA).

OPR identiﬁed Vehicle Miles Traveled (VMT) as the
new metric. The City of Riverside adopted VMT
thresholds in July 2020 following OPR’s guidance
which uses average VMT per person/employee as a
baseline for determining needed reductions. While
many development projects within the City are
screened out based on the City’s screening criteria,
some development projects cannot meet adopted
thresholds for reduced VMT.

The goal of this project is to establish a VMT
mitigation program for the City of Riverside so that
projects can reduce impacts from VMT to a less-
than-signiﬁcant level by paying into a program. This
project will provide the City with a citywide
mechanism to mitigate development projects that
cannot mitigate on-site, and simultaneously provide
additional funding for active transportation and
transit projects that help reduce VMT overall via a
banking or exchange program. In addition, one of the
primary beneﬁts of establishing a VMT Mitigation
Program is that it provides the City with the ability to expedite processing projects with identiﬁed VMT
impacts and minimize or eliminate the need for
additional environmental studies.
12/14/23, 10:20 AM City of Riverside Vehicle Miles Traveled Mitigation Program Project Survey https://www.surveymonkey.com/r/RiversideVMT 2/5
For more information including a project overview
video, please visit the project website:
https://riversidevmt.com/. The following document
also provides additional information on VMT and the
project: Additional Information on VMT

1. Are you a Riverside resident, business owner, or
both?
Resident
Business Owner
Both

2. Have you heard of Vehicle Miles Traveled (VMT)
before?
I have not heard of VMT prior to this survey.

I am aware of VMT policy but am not familiar with its
overall detailed requirements.

I am familiar with VMT state requirements

3. How do you feel about a fee program being
introduced to provide additional options for
development applicants to pay to reduce their
Vehicle Miles Traveled (VMT) impacts?
Yes, I support a developer fee program
No, I do not support a developer fee program
12/14/23, 10:20 AM City of Riverside Vehicle Miles Traveled Mitigation Program Project Survey https://www.surveymonkey.com/r/RiversideVMT 3/5

4. Would you prefer a program where fees are
charged based on the project size (e.g., number of
dwelling units for residential project or total square- feet for non-residential projects) or by the size of
their VMT impact (i.e., fees based on a project’s total VMT above the City’s threshold)? Note that in the
ﬁrst program type, fees are charged whether or not a
project has a VMT environmental impact.

Project size
Amount of VMT above threshold

5. Which types of mitigation projects are you most
excited about implementing? Please rank the
following options
Transit
Bicycle/Pedestrian
Land use (i.e., helping fund
aﬀordable housing or transit-
oriented development)
Reduced Demand (e.g., road diets,
lane restrictions, and traﬃc
calming)
12/14/23, 10:20 AM City of Riverside Vehicle Miles Traveled Mitigation Program Project Survey https://www.surveymonkey.com/r/RiversideVMT 4/5
Transportation Demand
Management measures (e.g.,
telecommuting programs,
carpooling programs, vanpool
programs, or charging for on-
street parking)

6. Which types of Transportation Demand
Management measures do you prefer most to
implement?
Vanpooling programs (employer/City provides a van
for multiple employees to use at no cost to the
employees)
Carpooling programs (employer/City sets up a
program that enables employees to coordinate
carpooling and provides a monetary incentive to the
driver of the carpool)
Telecommuting programs (City works with
employers to provide telecommuting options to
employees to enable them to telecommute one day
or more per week)

7. Do you prefer a VMT reduction program where a
portion of fees generated are required to be spent
locally (i.e., spent in the general area in which the
project is located), or one where funds are spent on
projects located throughout the region regardless of
where projects are located?
Local component
No local component
12/14/23, 10:20 AM City of Riverside Vehicle Miles Traveled Mitigation Program Project Survey https://www.surveymonkey.com/r/RiversideVMT 5/5
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8. Concerns have been raised about implementing a
fee-based VMT mitigation program. Please rank the
concerns below from most concerning to least
concerning in your option.

Project selection (i.e., identifying
feasible or cost-eﬀective projects)
Equity (i.e., ensuring the costs and
beneﬁts of a program are shared
equally throughout the region)
The potential for increasing the
cost of development
Gathering enough community or
decision-maker support to
implement the program
The potential legal issues or
complexity of the program
Done
City of Riverside Vehicle Miles Traveled Mitigation Program Project Survey 1 / 8
100.00% 15

0.00% 0

0.00% 0
Q1 Are you a Riverside resident, business owner, or both? Answered: 15 Skipped: 0
TOTAL 15
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Resident
Business Owner
Both

ANSWER CHOICES RESPONSES
Resident
Business Owner
Both
City of Riverside Vehicle Miles Traveled Mitigation Program Project Survey 2 / 8

46.67% 7

40.00% 6

13.33% 2
Q2 Have you heard of Vehicle Miles Traveled (VMT) before? Answered: 15 Skipped: 0
TOTAL 15
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
I have not
heard of VMT...

I am aware of
VMT policy b...

I am familiar
with VMT sta...

ANSWER CHOICES RESPONSES
I have not heard of VMT prior to this survey.

I am aware of VMT policy but am not familiar with its overall detailed requirements.

I am familiar with VMT state requirements
City of Riverside Vehicle Miles Traveled Mitigation Program Project Survey 3 / 8

40.00% 6

60.00% 9
Q3 How do you feel about a fee program being introduced to provideadditional options for development applicants to pay to reduce their VehicleMiles Traveled (VMT) impacts? Answered: 15 Skipped: 0
TOTAL 15
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Yes, I support
a developer ...

No, I do not
support a...

ANSWER CHOICES RESPONSES
Yes, I support a developer fee program
No, I do not support a developer fee program
City of Riverside Vehicle Miles Traveled Mitigation Program Project Survey 4 / 8

30.77% 4

69.23% 9
Q4 Would you prefer a program where fees are charged based on theproject size (e.g., number of dwelling units for residential project or totalsquare-feet for non-residential projects) or by the size of their VMT impact(i.e., fees based on a project’s total VMT above the City’s threshold)? Notethat in the first program type, fees are charged whether or not a projecthas a VMT environmental impact.

Answered: 13 Skipped: 2
TOTAL 13
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Project size
Amount of VMT
above threshold

ANSWER CHOICES RESPONSES
Project size
Amount of VMT above threshold
City of Riverside Vehicle Miles Traveled Mitigation Program Project Survey 5 / 8
Q5 Which types of mitigation projects are you most excited aboutimplementing? Please rank the following options Answered: 15 Skipped: 0

13.33%
2 33.33%
5 20.00%
3 26.67%
4 6.67%
1 15

3.20 33.33%
5 13.33%
2 33.33%
5 6.67%
1 13.33%
2 15

3.47 26.67%
4 13.33%
2 20.00%
3 13.33%
2 26.67%
4 15

3.00 26.67%
4 20.00%
3 13.33%
2 26.67%
4 13.33%
2 15

3.20 0.00%
0 20.00%
3 13.33%
2 26.67%
4 40.00%
6 15

2.13 0 1 2 3 4 5 6 7 8 9 10
Transit
Bicycle/Pedestr
ian
Land use
(i.e., helpi...

Reduced Demand
(e.g., road...

Transportation
Demand...
1 2 3 4 5 TOTAL SCORE
Transit
Bicycle/Pedestrian
Land use (i.e., helping fund affordable housing or transit- oriented development)
Reduced Demand (e.g., road diets, lane restrictions, and traffic calming)
Transportation Demand Management measures (e.g.,
telecommuting programs, carpooling programs, vanpool
programs, or charging for on-street parking)
City of Riverside Vehicle Miles Traveled Mitigation Program Project Survey 6 / 8

21.43% 3

7.14% 1

71.43% 10
Q6 Which types of Transportation Demand Management measures do youprefer most to implement? Answered: 14 Skipped: 1
TOTAL 14
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Vanpooling
programs...

Carpooling
programs...

Telecommuting
programs (Ci...

ANSWER CHOICES RESPONSES
Vanpooling programs (employer/City provides a van for multiple employees to use at no cost to the employees) Carpooling programs (employer/City sets up a program that enables employees to coordinate carpooling and provides a monetary incentive to the driver of the carpool)
Telecommuting programs (City works with employers to provide telecommuting options to employees to enable them to telecommute one day or more per week)
City of Riverside Vehicle Miles Traveled Mitigation Program Project Survey 7 / 8

92.86% 13

7.14% 1
Q7 Do you prefer a VMT reduction program where a portion of feesgenerated are required to be spent locally (i.e., spent in the general area inwhich the project is located), or one where funds are spent on projectslocated throughout the region regardless of where projects are located? Answered: 14 Skipped: 1
TOTAL 14
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Local component
No local
component

ANSWER CHOICES RESPONSES
Local component
No local component
City of Riverside Vehicle Miles Traveled Mitigation Program Project Survey 8 / 8
Q8 Concerns have been raised about implementing a fee-based VMTmitigation program. Please rank the concerns below from most concerningto least concerning in your option.

Answered: 15 Skipped: 0

13.33%
2 46.67%
7 20.00%
3 6.67%
1 13.33%
2 15

3.40 20.00%
3 13.33%
2 13.33%
2 20.00%
3 33.33%
5 15

2.67 40.00%
6 6.67%
1 6.67%
1 33.33%
5 13.33%
2 15

3.27 20.00%
3 26.67%
4 26.67%
4 20.00%
3 6.67%
1 15

3.33 6.67%
1 6.67%
1 33.33%
5 20.00%
3 33.33%
5 15

2.33 0 1 2 3 4 5 6 7 8 9 10
Project
selection...

Equity (i.e.,
ensuring the...

The potential
for increasi...

Gathering
enough...

The potential
legal issues...
1 2 3 4 5 TOTAL SCORE
Project selection (i.e., identifying feasible or cost-effective projects)
Equity (i.e., ensuring the costs and benefits of a program are shared equally throughout the region)
The potential for increasing the cost of development
Gathering enough community or decision-maker support to implement the program
The potential legal issues or complexity of the program Prepared for: Prepared by:

Vehicle Miles Traveled
(VMT) Mitigation
Through Fees, Banks & Exchanges Program
May 3, 2023
Stakeholder Advisory Meeting 1
Agenda
Background
Work
Plan
Task
Highlights
Schedule

Introduction to Project
What is VMT?
What issue is the City
addressing?
Why have we convened
the meeting?

Goals and Objectives
Goal: Develop a program that will successfully implement SB 743 & attainment of the Greenhouse Gas (GHG) reduction goals
Objectives:
Review other existing VMT Mitigation Programs to determine feasibility with implementing similar program measures
Substantiate the legal basis of a VMT fees, banks and exchanges program Establish a CEQA Nexus Study to reduce VMT impacts through a VMT mitigation exchange, banking program, or alternative program Establish a CEQA Nexus Study that determines a VMT Impact Fee per residential dwelling unit
Demonstrate the legal basis of a VMT exchange program Prepare Environmental Impact Report (EIR) document to update the City’s General Plan and incorporate the proposed VMT Mitigation Programs Senate Bill 150 (SB 150) Final Report
VMT = Vehicle Miles Traveled, SCS = Sustainable Communities Strategy History of Level of Service
First Edition of HCM published in 1950
There have been 6 editions
Significantly guided transportation decision-making
70 year later its application has been tied to
Urban Sprawl
Impacts to active transportation
Induced demand
VMT Analysis is sensitive to these challenges
We know how LOS affects outcomes
Genat, Robert (2003). Original Chevrolet, 1955, 1956, 1957 – The Restorer's Guide . Motorbooks International. p. 66. ISBN 0-7603-1548-5. Retrieved May 1, 2013.

Level of Service
7 Average
Delay
45 Seconds
Impact to the Driver Diver’s Impact to
Transportation System
4 vehicles travel 30 miles
or simply
4x30 = 120 VMT
120 VMT / 6
Drivers/Passengers =
20 VMT/Capita

LOS A B C D E F F
Highway Capacity Manual Travel Demand Model
Vehicle Miles Traveled
30 miles
Understanding
Image #2
Background

SB 743 Overview
State mandate for all local jurisdictions in California SB 743 is CEQA Specific
Basis for a “transportation significant impact” determination Sustainability and GHG reduction by
Denser infill development
Reducing single occupancy vehicles
Improved mass transit
Lead agencies have until July 1, 2020
Most recent guidance is from December 2018
Recommends that land uses be split out
VMT is the principal metric
Traffic Guidelines and VMT Screening
VMT Screening Criteria
Projects located in a Transit Priority Areas (TPA)
Projects located in a low-VMT generating area
Projects located in Housing element opportunity areas Local-serving K-12 schools and day care centers
Local parks
Local-serving gas stations, banks, hotels (e.g., non-destination hotels) Student housing projects
Local serving community colleges consistent with the assumptions noted in the RTP /SCS
Projects generating fewer than 110 daily vehicle trips Projects consisting of 100% affordable housing
Housing Element Opportunity Areas - Exempt from VMT

Riverside VMT Mitigation - Examples
Examples of VMT Mitigation for City Projects
Preferential Parking for Carpool and Vanpool
Carpooling and Vanpooling Program with Guaranteed Ride Home Program Transportation Service/Information Website & Trip Reduction Marketing Bus Stop Amenities
Telecommuting/Alternative Work Schedules
Transportation Coordinator as part of a Transportation Demand Management (TDM) Program
Subsidizing Transit Passes
Project Site Design
Bicycle Amenities & Active Transportation Improvements Wayfinding
Mitigation Challenges
Not all projects can be fully mitigated
EIR or MND recommended to address VMT impacts IF:
Project isn’t exempt per the city’s VMT screening criteria, AND Unable to use existing VMT mitigation toolbox
Causes long delays and expensive costs to applicants
VMT Mitigation Program should expedite application process Riverside is “Prohousing”
On April 6, Riverside was designated as “Prohousing” by the State One of only 22 communities in State with designation
Designation allows City to apply for $26 million Prohousing Incentive Program
City will receive preference in seeking state funding for programs designed to speed the production of housing
Provides priority processing or funding points when applying for housing grants
City has had success with housing grants in past with tens of millions already won Potential Project Mitigation Solutions
Bike/Ped New lane miles or filling in gaps
Transit New lanes miles, service types, or filing in gaps Land Use Examples include Affordable Housing, Transit
Oriented Development, or other Intuitional Needs
TDM Transportation Demand Measures (CAPCOA)
VMT Pricing
Solutions Toll Lanes, Cordon Pricing, Pricing per Mile
Reduced
Demand Road Diets, Lane Restrictions, Traffic Calming
TDM
Note: CAPCOA = California Air Pollution Control Officers Association Understanding
Image #2
Applicant Project Example
Understanding
Image #2
Example Project
Project Specific
Mitigation
Understanding
Image #2
How a VMT Bank Works
1,000,000k

Understanding
Image #2
How a VMT Exchange Works

How a VMT Impact Fee Works
Work Plan

Task 2.1 – 2.4: Literature Review
Safegurding Equity in Off-Site Vehicle Miles Traveled (VMT) Mitigation in California
VMT Program Bulletin 21-01: VMT Mitigation Funding Status And Additionality – State of California Department of Transportation An Analysis of Vehicle Miles Traveled Banking and Exchange Frameworks
VMT Mitigation Through Fees, Banks, and Exchanges
Implementing SB 743: An Analysis of Vehicles Miles Traveled Banking and Exchange Frameworks
Implementing SB 743: Design Considerations for Vehicle Miles Traveled Mitigation Bank and Exchange Programs
A Transaction-Based Alternative for VMT Mitigation Under CEQA The Potential for Regional Transportation Impact Mitigation Fee Programs and Mitigation Banks to Help Streamline the
Implementation of SB 743
San Diego Citywide Active Transportation In Lieu Fee Program Estimated Impacts and Cost Savings
City of San Jose Council Policy, Transportation Analysis Policy Tahoe Regional Planning Agency, Mobility Mitigation Fee Update San Francisco Transportation Sustainability Fee (TSF) Nexus Study
Transportation Impact Assessment (TIA) Fee Program Study for Coastal Transportation Corridor Specific Plan and West Los Angeles Transportation Improvement and Mitigation Specific Plans Amendment Project
California Department of Fish and Wildlife, Conservation and Mitigation Banking
Setting the Stage for Statewide Advance Mitigation in California California Legislative Information, AB 602 Development Fees:

Impact fee Nexus Study
State’s VMT Law Driving Builders Away, Making Homes More Expensive, Say Valley Lawmakers
With State VMT Law Limiting Home Building, Clovis Takes Action San Diego County Ponders a VMT Tax, with a Twist
Powering California, ANALYSIS: Vehicle Miles Traveled Tax (VMT) Relevant Superior Court of California Petitions
Highlight: Task 3.2 – Evaluation Criteria
Vehicle Miles Traveled (VMT) Mitigation
Through Fees, Banks & Exchanges Program
Highlights: Task 4 - Impact Tool

Highlight - Task 5.2: Technical Justification

Highlight - Task 5.2: Investment Tool/Screening

PROJECT ID PROJECT TITLE PROJECT DESCRIPTION EST TOTAL

PROJECT COST
Project distance
(miles)
Trips to Meet Target
Cost/VMT
Trips/Mi to Meet
Target Cost/VMT
SCCEX01 Bike Project 1 Convert Ex Street 1 from 4 Lanes to 2 Lanes with Buffered Bike Line in Both Directions $500,000 2.5 210 84
SCCEX02 Bike Project 2 Convert Ex Street 2 from 4 Lanes to 2 Lanes with Buffered Bike Line in Both Directions $800,000 4 336 84
Distance/Percent/C
ost Metric

2.38 City of Riverside Bike Dist

0.43 City of Riverside Ped Dist
67% Bike Share
33% Ped Share
$1,000 Target Cost/VMT

Task 6 - Outreach

Schedule
Vehicle Miles Traveled (VMT) Mitigation
Through Fees, Banks & Exchanges Program
Next Steps
Review of other existing programs
Prepare outreach plan
Next meeting is tentatively June 7th from 2 – 3 PM
Questions?
Chris Gregerson
[email protected]
Prepared for: Prepared by:

Vehicle Miles Traveled
(VMT) Mitigation
Through Fees, Banks & Exchanges Program
June 7, 2023
Stakeholder Advisory Meeting 2
Agenda
Remaining
Slides
Work
Plan
Task
Highlights
Schedule

Understanding
Image #2
Example Project
Project Specific
Mitigation
Understanding
Image #2
How a VMT Bank Works
1,000,000k

Understanding
Image #2
How a VMT Exchange Works

How a VMT Impact Fee Works
Pause for Questions
Work Plan

Task 2.1 – 2.4: Literature Review
Safeguarding Equity in Off-Site Vehicle Miles Traveled (VMT) Mitigation in California
VMT Program Bulletin 21-01: VMT Mitigation Funding Status And Additionality – State of California Department of Transportation An Analysis of Vehicle Miles Traveled Banking and Exchange Frameworks
VMT Mitigation Through Fees, Banks, and Exchanges
Implementing SB 743: An Analysis of Vehicles Miles Traveled Banking and Exchange Frameworks
Implementing SB 743: Design Considerations for Vehicle Miles Traveled Mitigation Bank and Exchange Programs
A Transaction-Based Alternative for VMT Mitigation Under CEQA The Potential for Regional Transportation Impact Mitigation Fee Programs and Mitigation Banks to Help Streamline the
Implementation of SB 743
San Diego Citywide Active Transportation In Lieu Fee Program Estimated Impacts and Cost Savings
City of San Jose Council Policy, Transportation Analysis Policy Tahoe Regional Planning Agency, Mobility Mitigation Fee Update San Francisco Transportation Sustainability Fee (TSF) Nexus Study
Transportation Impact Assessment (TIA) Fee Program Study for Coastal Transportation Corridor Specific Plan and West Los Angeles Transportation Improvement and Mitigation Specific Plans Amendment Project
California Department of Fish and Wildlife, Conservation and Mitigation Banking
Setting the Stage for Statewide Advance Mitigation in California California Legislative Information, AB 602 Development Fees:

Highlight - Task 5.2: Technical Justification

Highlight - Task 5.2: Investment Tool/Screening

PROJECT ID PROJECT TITLE PROJECT DESCRIPTION EST TOTAL

2.38 City of Riverside Bike Dist

0.43 City of Riverside Ped Dist
67% Bike Share
33% Ped Share
$1,000 Target Cost/VMT

Pause for Questions
Task 6 - Outreach

Outreach Plan
Virtual meetings with key stakeholders
WRCOG (1)
Individual City Meetings with Cities (3)/County of Riverside (1) UCR (1)
RTA (1)
RCTC (Metrolink) (1)
Project Website Materials (https://riversidevmt.com/) Project Instructional Video
Draft Background Information for Video
Project Updates
Kimley-Horn host website (City to link) – story map style One in person meeting Public Meeting (when plan is ready) Recording posted to the website
City Library

Ward Map

Pause for Questions
State of Practice
Existing VMT Mitigation Exchange/Bank Programs Reviewed SCAG
LADOT
SBCTA
CCTA
SGVCOG
City of Fresno
Southern California Association of Governments (SCAG)
- Los Angeles Department of Transportation (LADOT)
Developed a VMT Mitigation Program Framework
Currently testing a pilot VMT mitigation exchange program: U-Pass Project Applicant sponsors new student transit passes, paying LA Metro or lead agency to distribute the passes, scaling up to meet their VMT reduction needs. Funds must go towards new transit trips to qualify as a VMT-reducing mitigation action. (enroll new students, new unis, or expand U-pass)
Daily VMT reduction per pass: 0.09
Next steps: Further refinement of the Multi-Agency Mitigation Program Framework
San Bernardino County Transportation Authority (SBCTA)
In August 2022, A pilot VMT mitigation bank was proposed. Initially, the program would focus on incentivizing individuals to earn VMT reduction credits by making choices to reduce their travel. After establishing a verified home-based work trip (HBW) “baseline,” individuals who volunteer for the program can generate credits whenever they choose to telework for a particular day. The volunteers would need to live or work in the County. The verified VMT reduction credit would then be assigned an economic value and the volunteers would be paid a share of that value as an incentive for reducing their VMT. The purchased credit would be banked by SBCTA and then sold to development projects that would need mitigation.
Estimated cost: $0.05 -$0.08 per VMT
Additional projects and programs already established under the Inland Empire (IE) Commuter Rideshare Program could be added in the future (e.g. choices to ride transit or vanpool/carpool) Contra Costa Transportation Authority (CCTA)
In March 2023, a draft VMT mitigation framework has been released. CCTA has expressed interest in establishing a pilot hybrid exchange/in- lieu fee program targeted toward implementing the Mobility On Demand (MOD) app.
The MOD app would function as a voluntary commute trip reduction program and a source of community-based travel information.
The app offers the ability to monitor the VMT generation, hence quantifying the VMT effects. This would create the ability to directly calculate the program’s cost-effectiveness for VMT Estimated cost: $0.10 -$0.35 per VMT
If MOD proves to be effective, could use demonstrated VMT reductions and cost data as the basis for a future fee program San Gabriel Valley Council of Governments (SGVCOG)
No publicly available document on the framework or the progress. Project Timeline
Initiation: Fall 2021
Completion: Fall 2022
City of Fresno
In the final stages of determining the feasibility of the framework Currently determining which type of program would work best Initial findings point to a combination of a bank and exchange Several categories of projects have been developed
Tested at least 1 project from each category to see what the $/VMT is Finalizing outreach and environmental justice analysis and the range of fees
Fresno COG
In the final stage of developing the program framework Program expected to be a regional program with a local component Framework finalized second half of 2023
Several categories of projects have been developed
Transit, Active Transportation, Carpool/Vanpool, Affordable Housing Micro Banks
Funding for existing active transportation projects
Relatively small in terms of capital cost
Locations
City of Watsonville
City of Tracy
City of Salinas
City of Hollister
Pause for Questions
Schedule
Vehicle Miles Traveled (VMT) Mitigation
Through Fees, Banks & Exchanges Program
Next Steps
Develop Evaluation Criteria
Analyze Program Cost and Funding Period Commitment
SAC Meeting #3 – Tentatively Scheduled for July 12 @ 2 PM Questions?
Chris Gregerson
[email protected]
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Prepared for: Prepared by:

Vehicle Miles Traveled
(VMT) Mitigation
Through Fees, Banks, & Exchanges Program
September 26, 2024
Stakeholder Advisory Meeting 6

Agenda
• Review Study Purpose
• Outreach Efforts
• Program Recommendation
• Projects Reviewed & Recommended
• Program Options
• Program Cost Comparison
• Case Studies
• TREDLite VMT Demo
• Mitigation Timing Considerations
• Findings and Remaining Steps
Study Purpose
• Compliance for State Requirements for Transportation Impacts • Provide information about Vehicle Miles Traveled (VMT) • Address projects that have VMT impacts without solutions • Project Website: https://www.riversidevmt.com/
Outreach Efforts

Program Recommendation
• VMT Bank is the Recommended Framework
How a VMT Bank Works
Projects Reviewed
• 25 bike projects analyzed
• 13 pedestrian projects considered, 4 analyzed
• 14 transit operations projects screened
• 6 transit projects analyzed
• 3 TDM projects from SCAG TDM Program considered
• Carpool – not analyzed
• Telecommute: Work-from-Home (WFH) every day vs. WFH 1 day a week • Analyzed
• Free Transit Pass – not analyzed
Bike Projects
< $3,000/VMT
Reduced
(Recommended
for Inclusion in
Program)
Source:

Riverside Active
Transportation Plan,
Figure 4-30
7 Option A Program (Recommended) Summary Table
Roadway Ward Description Cost
(20-years)
VMT
Reduced Cost/VMT
Columbia Ave 1 Stripe bike lane between American Dr and Salmon River Rd $110,067 90 $1,219
Brockton Ave 3 Stripe bike lane between Magnolia Ave
and Beatty Dr $91,877 593 $155
Orange St 1 Construct separated bikeway between
14th St and 3rd St $42,834 733 $58
Rutland Ave 6 Construct bicycle boulevard between
Wells Ave and Arlington Ave $178,573 1,058 $169
Colorado Ave 5 Stripe bike lane between Van Buren Blvd
and Monticello Ave $1,115,343 646 $1,728
Hole Avenue 6 Stripe bike lane between Tyler St and
Magnolia Ave $1,268,066 450 $2,816
University Ave 2 Construct a buffered bike lane between Iowa Ave and Campus Dr $1,001,921 750 $1,336
Total $3,808,681 4,320 $882
Note: Option A includes bike improvements only
Option B Program Summary Table
Roadway/Route Ward From/To or Route Name Cost (20-years) VMT Reduced Cost/VMT Columbia Ave 1 Stripe bike lane between American Dr and Salmon River Rd $110,067 90 $1,219
Brockton Ave 3 Stripe bike lane between Magnolia Ave and Beatty Dr $91,877 593 $155 Orange St 1 Construct separated bikeway between 14th St and 3rd St $42,834 733 $58 Rutland Ave 6 Construct bicycle boulevard between Wells Ave and Arlington Ave $178,573 1,058 $169
Colorado Ave 5 Stripe bike lane between Van Buren Blvd and Monticello Ave $1,115,343 646 $1,728
Hole Avenue 6 Stripe bike lane between Tyler St and Magnolia Ave $1,268,066 450 $2,816 University Ave 2 Construct a buffered bike lane between Iowa Ave and Campus Dr $1,001,921 750 $1,336
10 Riverside/Watkins-Galleria $5,900,000 2,285 $2,582
12 Corona Hills Plaza/Riverside/La Cadena-Merced $5,900,000 3,553 $1,660 13 Hunter Park Metro-Galleria $5,900,000 2,990 $1,973
14 Galleria-Loma Linda VA $5,900,000 3,142 $1,878
15 Riverside/Downtown-Merced $5,900,000 4,227 $1,396
22 Riverside - Perris $5,900,000 2,797 $2,109
Total $39,208,681 23,315 $1,682
Note: Option B includes bike and transit improvements only Option C Program Summary Table
Roadway/Route Ward From/To or Route Name Cost (20-years) VMT Reduced Cost/VMT Columbia Ave 1 Stripe bike lane between American Dr and Salmon River Rd $110,067 90 $1,219 Brockton Ave 3 Stripe bike lane between Magnolia Ave and Beatty Dr $91,877 593 $155 Orange St 1 Construct separated bikeway between 14th St and 3rd St $42,834 733 $58 Rutland Ave 6 Construct bicycle boulevard between Wells Ave and Arlington Ave $178,573 1,058 $169 Colorado Ave 5 Stripe bike lane between Van Buren Blvd and Monticello Ave $1,115,343 646 $1,728 Hole Avenue 6 Stripe bike lane between Tyler St and Magnolia Ave $1,268,066 450 $2,816 University Ave 2 Construct a buffered bike lane between Iowa Ave and Campus Dr $1,001,921 750 $1,336 10 N/A Riverside/Watkins-Galleria $5,900,000 2,285 $2,582 12 N/A Corona Hills Plaza/Riverside/La Cadena-Merced $5,900,000 3,553 $1,660 13 N/A Hunter Park Metro-Galleria $5,900,000 2,990 $1,973 14 N/A Galleria-Loma Linda VA $5,900,000 3,142 $1,878
15 N/A Riverside/Downtown-Merced $5,900,000 4,227 $1,396 22 N/A Riverside - Perris $5,900,000 2,797 $2,109
Orange Street 1 Complete street with 5.5-foot sidewalks between SR-60 and Center Street $1,000,000 24 $41,667
Main St 1 Complete street with 5-8-foot sidewalks between Columbia Ave and Santa Ana River $2,000,000 30 $66,667
Total $42,208,681 23,369 $1,806
Note: Option C includes bike, transit, and pedestrian improvements Program $/VMT Reduced Comparison
Agency VMT Mitigation
Program Format Status Cost per VMT Reduced
($/VMT Reduced)
City of Lancaster VMT Mitigation Fee
Optional Program Implemented in 2023, with a cost basis of $150/VMT $425/VMT reduced Los Angeles County State
Highway System VMT Bank Implemented 2024, with a cost basis of $261/VMT. -- City of Palmdale VMT Bank Study completed. Pending adoption and implementation. $261/VMT reduced City of Salinas Active Transportation In-
Lieu Impact Fee Implemented in 2020, with a cost basis of $1,400/VMT. -- City of Tracy VMT Bank Implemented March 2023, with a cost basis of $1,524/VMT --
City of Watsonville TBD Study funded under REAP 2.0. Not yet started. $1,524/VMT reduced (maximum)
Case Study Example 1
• Wood and Lurin Residential Project
• 96 residential units, 3.28 persons per household, 315 project population • Project VMT/capita = 19.0, City threshold = 9.18 VMT/capita • Equates to 3,093 VMT to mitigate
• Option A would provide enough VMT to fully mitigate the impact • Option A results in a total cost to mitigate of $2,728,000 or $28,400 per household
• Option B would result in a total mitigation cost of approximately $5,202,400 or $54,190 per household
• Option C would result in a total mitigation cost of approximately $5,585,950 or $58,190 per household
Case Study Example 2
• Kaiser Permanente Regional Hospital Project
• Expand existing facility by approximately 296,000 square-feet • VMT analysis required 9,316 VMT to mitigate
• Option A would not provide enough VMT to fully mitigate the impact, but Option B and Option C do provide enough VMT to fully mitigate
• Option B would result in a total mitigation cost of approximately $15,669,500 or $52.94 per square-foot
• Option C would result in a total mitigation cost of approximately $16,824,700 or $56.84 per square-foot
Case Study Findings
• A mitigation bank may not make all projects financially feasible for mitigation
• Reducing the cost of VMT mitigation can make more projects financially feasible
• Selecting mitigation measures that provide effective VMT reduction at a lower cost
• Using the VMT bank to cover funding gaps, where other funding sources reduce overall costs
TREDLite VMT Demo

Mitigation Timing Considerations
• Agencies need to be diligent in managing VMT mitigation timing • Bank arrangements that receive pooled funds from multiple projects should account for the delay between payment and the deployment of funds
• Agencies must ensure that the timing of the implementation of mitigation measures aligns closely with the development impact to maintain the essential nexus and proportionality
Findings and Remaining Steps
Findings
• VMT Banking would be the most appropriate initial program • Three program options with different mixes of mitigation measures were developed
• Option A with only bike improvements and the lowest $/VMT is recommended
• Methods for evaluating VMT mitigation for various mitigation measures have been established
• Remaining Steps
• Committee Presentations
• Council Presentations and Adoption
Questions?

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City of Riverside
VMT Mitigation Program
Appendix D: Riverside TREDLite VMT Quick Guide

QUICK START GUIDE
TREDLite VMTRiverside
A Kimley-Horn Sustainable Transportation Solution
This help file describes the main concepts, vocabulary, and application functionality.

Note that the data used to develop TREDLite VMT Riverside is based on the current version of WRCOG's travel demand model, RIVCOM, as of October 17, 2024.

The VMT analysis results obtained from the use of this tool may differ from WRCOG's VMT Analysis Tool.

Getting Started
TREDLite (windows.net) Click this link to launch the demo site from your browser

CALLOUT KEY
Callouts in blue highlight
key instructions or
considerations
Callouts in green provide
general guidance or
instructionsClick “Accept” to continue
Few things to note:
TREDLite relies on travel demand model data from that has been processed by Kimley-Horn Thresholds are based on OPR guidance and are established for each jurisdiction separately (Unincorporated County and Cities) Sometimes there are “blanks” in the data given that there is no existing data for a land use (something we can address in a full implementation) Click “Single” to pick a specific parcel
Select Jurisdiction and
map will zoom to that area
Option to either enter project address
or select parcel using the toggle below
Note: you must zoom in (use mouse
scroll wheel) to display the parcel layer
to see and select an individual parcel
Click “Next”
to proceed.

Activate colored/hatched theme maps,
showing VMT/Capita or VMT/Employee based
on thresholds established for the jurisdiction
and/or the location of disadvantaged
communities.

Enter a project name to proceed.

Note: that this is a required input
Select analysis year
Select project land uses
(up to 10 land uses can be added)
Enter land use quantity
Click to add project land uses
Click “Calculate” to proceed
Note: that if only a single land use · »²¬»®»¼ ¬¸· ½®»»² ©·´´ ²±¬ ¿°°»¿®ò Ì¸· ³±¼«´» ¿´´±© º±® ¿²¿´§· ±º ·²¬»®²¿´ ½¿°¬«®» ¿ ·³°´»³»²¬»¼ ¾§ ÒÝØÎÐ êèì øÌ®¿ª»´ Ü»³¿²¼ Ó±¼»´ ¼± ²±¬ ¬§°·½¿´´§ ¿¼¼®» ·¬» °»½·º·½ ·²¬»®²¿´ ½¿°¬«®» »ºº»½¬÷ò
If desired to override the default NCHRP 684 method, select “Custom” to enter Internal Capture Rates in the box below Enter custom project specific % for internal
capture (if default method is overridden)
Click “Calculate” to proceed
Graph shows VMT result & threshold
for each land use
Select land use tab to toggle between individual uses
Note: Air quality is shown both in the aggregate and for individual uses and includes both mobile and non mobile sources
This is being implemented
in
Click “Mitigate VMT”
if it is over the threshold
Select land use tab to toggle between
Individual uses (land uses are mitigated
individually as not all mitigations are
appropriate for all land uses.)
Click to expand each
TDM category
Results of each TDM
based on data entered
Although the new 2021 CAPCOA guide does not include maximum value guidance, we still recommend setting them at the TDM level, the TDM category level, and for the total TDM reduction Enter project specific
inputs for applicable TDM
Click to proceed to VMT Banking
if VMT is over threshold

Enter Feasible Mitigation % to test the
effect on hypothetical or real projects
Click “Print Results” to capture
a PDF of inputs and outputs
Enter cost in VMT/$ to test
the effect of different costs
on hypothetical or real projects
Note: this is currently setup to
facilitate the study of VMT
mitigation options. Prior to
public release, the values can
be hardcoded or the module
can be removed if desired
Select land use tab to toggle
between individual uses

Copyright 2023, All Rights Reserved .
web https://tredlite.kimley-horn.com/sites/riverside
email [email protected]
[email protected]
[email protected]
[email protected]
City of Riverside
VMT Mitigation Program
Appendix E: VMT Mitigation Bank Program and CEQA
Clearance
VMT Mitigation Bank Program and CEQA Clearance
Kimley-Horn and Associates, Inc. for City of Riverside
July 8, 2024
DRAFT
Introduction
Kimley-Horn has prepared this document to summarize ongoing discussions regarding potential CEQA documentation options for the VMT Mitigation Bank Program and associated tiering implications for future VMT Mitigation Projects and future development and transportation projects (“applicant projects”). Note this is not provided as a legal opinion but rather as a summary of what is understood from conversations surrounding this and other similar projects. The key questions and a summary of our understanding is provided below:
1 .W hat is the most appropriate CEQA documentation for the proposed “ VMT Mitigation Program” ? There has been some conflicting information in the industry on whether environmental clearance is required given that both the “applicant’s project” and the “VMT Mitigation Projects” require that CEQA be addressed and as such there is the question as to whether the “VMT Mitigation Program” would accordingly require clearance. Further adding to this confusion, many existing fee programs, such as transportation impact free programs, do not require CEQA clearance as part of their reoccurring updates. Additional discussion regarding this is provided in Appendix A. Note that this discussion is general in nature and does not presume a final format of the VMT Mitigation Program.

Regardless of a final determination as to whether it is legally required to prepare CEQA documentation for a VMT Mitigation Program, it is Kimley-Horn’s understanding that the City would prefer to have some level of CEQA documentation prepared in order to clearly demonstrate that CEQA requirements were considered and that the VMT Mitigation Program does not have an environmental impact.

2. To what extent should the proposed “ VMT Mitigation Projects” (projects to be funded by the VMT Mitigation Program) have CEQA evaluation completed as part of the current scope of services. It is understood that the individual projects require CEQA consideration. However, the projects, based on preliminary review and as discussed are anticipated to qualify for a CE, and there would be no need to adopt a “Statement of Overriding Considerations.” Assuming this is the case, the individual VMT Mitigation Projects could likely be cleared within the existing budget of this study depending on the final approach to CEQA that is determined.
3 .W hat a pproaches a re a vailable t o e stablish a d efined “ feasible m itigation” l imit i n t erms o f a n applicant’s p roject, t hat h as b een f ound t o h ave a “ significant i mpact” , b eing r equired t o participate in the proposed VMT Mitigation Program? In practice, the existence of a VMT Mitigation Program establishes “feasible mitigation” that must be considered for any applicant’s project that has a significant impact and that does not have alternate solutions to address that significant impact prior to seeking an overriding consideration. Under these circumstances, an applicant’s project would be required to participate in the VMT Mitigation Program to the extent necessary to mitigate their project’s impact or to the extent it becomes infeasible. As a practical matter the determination of when it becomes infeasible is a determination as to the point at which the next incremental cost of mitigating an applicant’s project through the VMT Mitigation Program becomes “unaffordable". The existence of VMT Mitigation Program could result in the City being asked by individual project applicants to make a determination as to whether their claim of unaffordability is appropriate. Any applicant’s project that is not fully mitigated through participation in the VMT Mitigation Program (assuming there it is agreed to by the City that the next incremental cost of mitigating an applicant’s project is unaffordable) would still be required to pursue an overriding consideration.

To avoid the potential for the City having to address claims related to the feasibility of the mitigation (affordability), it is desired to establish a predefined maximum limit that a project applicant would be required to participate in the program. It is envisioned under these circumstances that an applicant could still participate to the level necessary to fully mitigate their project to avoid the requirement to seek overriding consideration but that would not be a requirement. An initial discussion on approaches to establishing a feasible mitigation limit included the following:

The upcoming General Plan update may provide an opportunity to establish a feasible mitigation limit. It was understood from the discussion that the establishment of a feasible mitigation limit may require a General Plan amendment as its establishment would introduce a new General Plan policy. The impacts of that policy would be studied as part of the General Plan Update Environmental Impact Report.

There was some additional discussion regarding whether a finding of overriding considerations for this policy would create an opportunity for future applicant projects to subsequently tier off the General Plan EIR, allowing them to provide a lesser level of CEQA documentation (potentially an MND?) if they (1) had a significant impact related to VMT; and (2) participated in the VMT Mitigation Program (or some combination of mitigations) up to the feasible mitigation limit irrespective of the fact that they would not fully mitigate their VMT impact. The passage is provided in italics for the purpose of highlighting this as an area for future discussion/clarity.

The prior or current version of the CAPCOA’s Handbook for Analyzing Greenhous Gas Emissions Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity could be useful in establishing the maximum feasible mitigation limit. There has been some precedence elsewhere by agencies to use this document to establish feasible limits of mitigation.

Current Study’s Options
In terms of the current study the following options resulted from the initial discussion.

Option A: Option A is to prepare a Categorical Exemption (CE) for the VMT Mitigation Program and then a CE for each individual VMT Mitigation Project (preliminary review of currently identified VMT Mitigation Projects suggests that each individual VMT Mitigation Project would qualify as a CE, so that both the VMT Mitigation Program and the VMT Mitigation Projects it will initially fund would qualify for a CE). For the purposes of CEQA, the “Project” is the VMT Mitigation Program and associated specific VMT Mitigation Projects. As these physical VMT improvement projects are themselves anticipated to qualify for a CE, there would be no need to adopt a “Statement of Overriding Considerations.”
Future applicant projects could rely on the Program and CE to provide substantial evidence regarding the availability of reasonable and feasible mitigation and could offset VMT impacts by paying into the VMT Mitigation Program. See below for discussion on tiering where an applicant’s project identifies unavoidable significant VMT impacts.

Option B : City staff identified an interest in preparing a Program EIR for the VMT Mitigation Program and then tiering off the EIR for future applicant projects. According to OPR guidance on MNDs and tiering (page 9) - C. Tiering, CEQA Guidelines § 15152 and § 21083.3 of the Public Resources Code allow a Negative Declaration to be adopted when an EIR has previously been prepared for a program, policy, plan or ordinance. “The later project must be consistent with that program or other action and must not result in any significant effects which were not examined in that previous EIR. In order to tier from an EIR, the later project must be consistent with the general plan and zoning of the applicable city or county. The Negative Declaration must clearly state that it is being tiered upon a previous EIR, reference that EIR, and state where a copy of the EIR can be examined. These requirements apply equally to MNDs. Of course, any potential significant effects that were not examined in the previous EIR must be avoided or completely mitigated if a MND is to be adopted. A MND is not recommended when the document on which it is being tiered has identified unavoidable significant cumulative effects.” For future VMT Mitigation Projects, these could easily tier off of the Program EIR, as long as they are consistent with VMT Mitigation Projects identified in the Program EIR. These future VMT Mitigation Projects could also simply prepare project-specific Categorical Exemptions where appropriate. Should additional VMT Mitigation Projects be identified, these may require additional CEQA review (broad categories of VMT mitigation could be included in the Program EIR to minimize the need for further CEQA review).

With respect to future applicant projects tiering off of the Program EIR, upon further consideration and research, we have the following comments and questions:

Where a future development project has less than significant VMT impacts or is able to mitigate VMT impacts, then this is a moot point. The Program and associated CEQA document could be cited as background on VMT mitigation options within the City, but in this case the VMT Mitigation Program would not be needed.

Where a future development project has significant VMT impacts, is not able to fully mitigate those impacts as part of the Project, these projects could obtain additional VMT mitigation by paying into the VMT Mitigation Bank Program. The development project CEQA document can cite to the Program EIR for VMT background and evidence for availability of reasonable and feasible mitigation. However, the development project CEQA document will need to demonstrate that the VMT impact is mitigated to less than significant levels, and if not, prepare a SOOC. We’d like the City’s further input on tiering off the Program EIR where a development project identifies an unavoidable significant impact, as the EIR for the VMT Mitigation Program would not have evaluated all land development projects (future buildout) within the City (refer to bold/italics section from OPR guidance cited on the previous page).

Appendix A – CEQA Requirements for VMT-Based Mitigation Fee Programs Lead agencies are pursuing a range of strategies to implement VMT-based mitigation fee programs.

Approaches that lead agencies are taking for VMT impact fees include: (1) impact fee programs that fund VMT-reducing projects without establishing a VMT “nexus” (the nexus is the basis for identifying impacts to be addressed by the program); (b) establishing a VMT nexus for identifying facilities need and cost allocation; and (c) establishing a fee program that links to systematic CEQA-reviewed VMT analysis in the General Plan and/or other related CEQA-reviewed citywide policy documents. These different approaches are factors in the determination of whether a City’s proposed VMT Mitigation Fee Program would be subject to the general provisions of CEQA.

A City could potentially find that a fee program is not a “project” under CEQA and is therefore exempt pursuant to CEQA Guidelines Section 15378 (b)(4); and is not intended to apply to specific capital improvement projects, and as such it would be speculative to evaluate such projects now; and/or is not intended to, nor does it provide CEQA clearance for future development-related projects by mere payment of the fees.

As set forth in CEQA Guidelines Section 15002, “CEQA applies in situations where a government agency can use its judgment in deciding whether and how to carry out or approve a project. A project subject to such judgmental controls is a “discretionary project”. For a fee program, a City could use its judgment in deciding whether and how to carry out or approve the program, and therefore the fee program would be a discretionary action. However, a fee program is not necessarily a “project” pursuant to CEQA. CEQA Guidelines Section 15378 provides that: “A project means the whole of an action which has the potential for resulting in either a direct physical change in the environment, or a reasonably foreseeable indirect physical change in the environment.” Whereas CEQA Guidelines Section 15378(b)(4) further provides that:
“ A project does not include . . . the creation of government funding mechanisms or other government fiscal activities which do not involve any commitment to any specific project which may result in a potentially significant physical impact on the environment.”
If the fee program is intended to create a funding mechanism but the fee program does not include any specific commitment to an individual project or any specific collection of individually identified projects, the City could determine it is not a project under CEQA. It is important to note that fees set by ordinance without a CEQA evaluation do not presumptively establish full mitigation for a discretionary project. If a mitigation program is not fully funded so as to fully mitigate an impact to an insignificant level, based on substantial evidence that it can do so, then it might be open to challenge as a basis for more than partial mitigation.

CEQA Guidelines Section 15273(b) notes that fees or rate increases to fund capital projects that provide for “expansion of a system” are subject to CEQA. Again, the objectives and detail of the VMT Mitigation Fee Program will determine whether the project would be subject to CEQA or could be exempt. For example, if specific improvements are identified, do these result in the expansion of the transportation system that have been previously identified as mitigation measures in prior CEQA documents? These transportation system expansion projects have already undergone CEQA review and no further environmental analysis is required unless (pursuant to CEQA Guidelines Section 15162) there are changes in the description of these planned transportation system projects, changes in circumstances, or new information which indicates that there are new or substantially more severe environmental impacts that could occur upon their implementation. Another approach would be to tier from the City’s adopted Climate Action Plan CEQA documentation.

Unless cleared through prior CEQA documentation, specific improvements would be subject to environmental review at such time as approvals for those projects are considered. Individual VMT projects may, or may not be found to be individually exempt from CEQA on the basis of their unique characteristics.

That decision can only be made at a later date, when the investment in a specific project is identified.

City of Riverside
VMT Mitigation Program
Appendix F: Categorical Exemption (CE) for the City
of Riverside VMT Mitigation Program
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ATTACHMENT A
City of Riverside VMT Mitigation Program Project Page 1 CEQA No ce of Exemp on A achment A July 2024

ATTACHMENT A

BACKGROUND, PROJECT DESCRIPTION AND JUSTIFICATION FOR CEQA EXEMPTIONS

1.0 PROJECT BACKGROUND
In 2013, SB 743 was signed into law which required the Governor’s Office of Planning and Research (OPR) to establish a new metric for identifying and mitigating transportation impacts for projects that are subject to the California Environmental Quality Act (CEQA). OPR identified Vehicle Miles Traveled (VMT) as the new metric. In accordance with SB 743 and the OPR’s designated VMT metric, the City of Riverside (City) adopted VMT thresholds in July 2020. Many of the development projects within the City are screened out based on the City’s existing screening criteria; however, some development projects cannot meet adopted thresholds for reducing VMT.

To encourage reductions in VMT, the City has analyzed various types of fee-based VMT mitigation programs, such as VMT banks, VMT exchanges, and VMT impact fee programs. VMT banks are established by implementing VMT-reducing projects within the City, such as improving pedestrian and bicycle facilities within the City. The VMT reductions are then placed in a “bank” with an associated fee that a development project would “purchase” to offset VMT that would be generated as a result of project implementation.

VMT exchanges work similarly, with the main difference being that applicants have the option to choose a single project from an existing list or program of VMT-reducing projects or propose a VMT-reducing project for implementation that may not appear on said list. The program that is chosen or proposed would have to meet the minimum VMT reductions that the project would generate. VMT impact fee programs would function similarly to how existing development fee programs work. In this case, a development project would be required to pay a fee to offset its VMT impact.

Based on the results of the analysis, the VMT bank program would be the recommended framework for the City’s future VMT Mitigation Program. The VMT bank program would address all reasonable and feasible VMT mitigation opportunities. Compared to all other VMT Mitigation Programs, the VMT bank can successfully address legal, effectiveness, geographical, administrative, equitable, and alignment concerns. Additionally, the VMT bank would best reduce complexity and allow for concerns around equity to be addressed by public agencies.

2.0 PROJECT DESCRIPTION
Project Location – Specific
The VMT bank program would be implemented in the City of Riverside and would be applicable to all future discretionary development projects proposed within the City, that are subject to CEQA, and that have been determined to have a significant VMT impact. The program is voluntary, in that individual projects may choose to address VMT impacts on a project-by-project basis.

Existing Conditions
Currently, there is no City-wide VMT mitigation program implemented that would help reduce VMT within the City. Where a significant VMT impact has been identified, at present the available VMT mitigation options for applicants are to modify the proposed development project such that impacts to VMT are

ATTACHMENT A
City of Riverside VMT Mitigation Program Project Page 2 CEQA No ce of Exemp on A achment A July 2024
reduced, implement Transportation Demand Management or other VMT-reducing measures, or if those two options are not available, prepare an Environmental Impact Report (EIR) and adopt a Statement of Overriding Considerations.

Project Operations
The VMT bank program would be established by calculating a fee per VMT. This can be done by first identifying VMT-reducing projects and evaluating the extent of reduction for each identified project. The total reductions from all projects are combined to calculate the total mitigated VMT, which would then become the VMT bank, or the amount of VMT available for projects to “buy” to offset project generated VMT. To determine the cost to mitigate future VMT, the associated costs of each VMT-reducing project are summed; the sum is then divided by the total VMT reductions (from VMT-reducing projects). Once the available VMT is used by development projects purchasing from the VMT bank, the VMT bank would need to be replenished with new VMT-reducing projects added.

The VMT bank program would be an opt-in program that would contain both physical and non-physical improvements. The City would only be committed to implementing or constructing VMT mitigation measures once enough developers have paid into the program. It would then be within the City’s jurisdiction to choose which mitigation measures to implement or construct.

Description of Nature, Purpose, and Beneficiaries of Project Purpose and Need
While many development projects within the City can be screened out based on the City’s existing VMT screening guidelines, some development projects may not meet the threshold criteria for reduced VMT.

As such, the VMT bank may serve as a mitigation program that would allow the City to offset future unavoidable VMT generation within the City as a result of future development projects. The City can invest in VMT-reducing projects, such as those improving and increasing alternative modes of transportation within the City (bicycle lanes, pedestrian facilities, public transit improvements, etc.). Based on the total cost of the VMT-reducing projects and the total reduction in VMT resulting from such projects, the VMT bank would allow those development projects that cannot feasibly mitigate the VMT to pay for the VMT that cannot be reduced. The purpose of this VMT mitigation program would be to reduce overall VMT within the City to less-than-significant levels.

Beneficiaries of Project
Reducing VMT would reduce greenhouse gas emissions and help reduce air quality impacts due to the decreased reliance on motorized vehicles and associated reduction in vehicular-oriented emissions.

Additionally, the VMT mitigation program would allow the City to invest in alternative transportation projects that would provide diverse transportation opportunities for residents and businesses, further reducing reliance on vehicular travel. Planned pedestrian and bicycle facility improvements as well as improved public transit projects can improve the circulation system within the City and improve traffic in high-volume areas. The VMT bank would also allow the City to expedite processing projects with identified VMT impacts and minimize or eliminate the need for additional environmental studies. By utilizing the VMT bank, the City can directly use the money obtained from the VMT fees paid by development projects to fund more VMT-reducing projects.

ATTACHMENT A
City of Riverside VMT Mitigation Program Project Page 3 CEQA No ce of Exemp on A achment A July 2024

3.0 REASONS WHY THE PROJECT IS EXEMPT
Applicable CEQA Exemptions
Section 15262 (Feasibility and Planning Studies) states that “a project involving only feasibility or planning studies for possible future actions which the agency, board, or commission has not approved, adopted, or funded does not require the preparation of an EIR or Negative Declaration but does require consideration of environmental factors. This section does not apply to the adoption of a plan that will have a legally binding effect on later activities.”
In addition, the Project is exempt pursuant to the “common-sense” exemption found in CEQA Guidelines Section 15061(b)(3). The common-sense exemption applies to projects that don’t necessarily fit within a statutory or categorical exemption, but “where it can be seen with certainty that there is no possibility that the activity in question may have a significant effect on the environment,” the activity is exempt from CEQA (CEQA Guidelines Section 15061(b)(3).

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Riverside City CouncilDecember 17, 2024

Riverside City Council
December 17, 2024